Getting to Know the 2025 CSP Amendment: What Was Modified on May 16?

There is a significant update that you should be aware of, whether you work with businesses registered in Malta or are simply interested in business legislation. A substantial change to Malta’s Company Service Provider (CSP) rules, particularly regarding directors and company secretaries, was introduced on May 16 2025.

Stay with us before dismissing the idea of discussing compliance. This update may have a greater impact on you than you realize.

Certain people who serve as directors or secretaries of Malta-registered businesses but do not do so as their primary business activity are required by the Malta Financial Services Authority (MFSA) to file a notification via the MFSA-licensed portal. Although it’s a simple procedure, things become a little more complicated when it comes to the laws regarding who must and cannot be notified.

Let’s try to disentangle everything as amicably as we can.

Who Is Exempt from Notifying the MFSA and Who Must?

 Fortunately, the MFSA has made it clear which people are exempt from notifying them. This is a straightforward summary of who is exempt:

 You won’t receive an MFSA notification if:

• You serve as a Director or Secretary on behalf of a licensed CSP.
• You are a shareholder or UBO, meaning you own shares in the business you work for.
• You work for the company or will soon work for it.
• You are a part of the UBO’s family.
• Even though your company is located overseas, you are a professional director or secretary by trade (however, keep in mind that these people now require a restricted CSP authorization in Malta).
• You are a board member of a publicly traded corporation.

❗ It is imperative that you notify us if

• You don’t qualify for the exemptions above because this isn’t your primary business.
• Notification is necessary even for a single appointment.

Therefore, it’s time to register your position on the MFSA portal if you’re functioning informally as a company director or secretary in Malta and none of the exemptions apply to you.

Process, Deadlines, and What to Expect

Let’s discuss logistics and timeframes because failing to do so could cause problems later.

Deadlines:

• Current Businesses: By July 16, 2025, notice must be given.
• New Businesses: After registering, you have 14 days to notify.

 The good news? We can use our MFSA license holder site to send this notification on your behalf if you’re working with a CSP like us.

Additionally, please note that you are still required to report if you are a foreign service provider—such as some of our South African partners—and you are assigning directors to Maltese firms without a CSP license in Malta.

What’s the CSP’s Role in This Update?

One thing has been made very clear by the MFSA: licensed CSPs are required to notify their clients, both present and potential, about this law; nevertheless, we are not responsible if clients disregard it.

What we’re doing is as follows:

• Looking through our customer list to find businesses that need to be notified by directors or secretaries.
• Supplying direction and assistance to facilitate the notification procedure.
• Ensuring that our staff notifies customers during discussions, particularly when new directors or secretaries who are not UBOs or their family members are being considered.

We can be thought of as your helpful compliance companion, alerting you to potential regulatory surprises.

If you have any questions, please do not hesitate to contact us.