In July 2025, the Maltese Parliament approved a historic bill that will alter the country’s approach to citizenship forever. With Legal Notice 159 of 2025, Malta is abolishing citizenship-by-investment (CBI) programs for a system founded upon Malta Citizenship by Merit 2025 (CBM).
The bill is both a direct response to the European Court of Justice (ECJ) ruling on exceptional services schemes and a proactive redesign of Malta’s international role within the investment migration industry. The bill replaces the Individual Investor Program (IIP) and the Malta Exceptional Investment Naturalisation (MEIN), and it officially closes the transactional era of Maltese citizenship.
This fast-tracked bill includes broader eligibility, elimination of stringent financial targets, strengthening review mechanisms, and codifying appeal procedures. It underscores Malta’s reorientation to merit-based recognition of exceptional services and contributions in alignment with Vision 2050 for sustainable economic growth and international credibility.
Extended Professional Categories and Definitions under Malta Citizenship by Merit 2025
New Sectors in Malta Citizenship by Merit 2025
Under Article 10(9), Malta Citizenship by Merit 2025 significantly broadens eligibility by formally recognising individuals whose professional achievements demonstrably advance Malta’s national interest. Unlike prior citizenship frameworks, eligibility under Malta Citizenship by Merit 2025 no longer revolves around capital deployment or investment status. Instead, it focuses on measurable excellence, societal contribution, and long-term strategic value to the country.
The updated legislation expressly includes the following merit-based categories under Malta Citizenship by Merit 2025:
Innovators, including leading researchers, scientists, and academic contributors whose work strengthens Malta’s innovation ecosystem.
Cultural figures and elite sports professionals who enhance Malta’s international profile and cultural diplomacy.
Entrepreneurs, founders, and technologists whose expertise improves national competitiveness, productivity, and economic resilience.
Philanthropists whose sustained social initiatives deliver tangible benefits to Maltese society, education, or public welfare.
Notably, Malta Citizenship by Merit 2025 deliberately removes the term “investor” from its legal vocabulary. This linguistic and structural shift confirms Malta’s strategic departure from citizenship-by-investment models and reinforces a citizenship framework grounded exclusively in merit, excellence, and contribution aligned with Malta’s long-term national objectives.
Ministerial Discretion in Malta Citizenship by Merit 2025
The Act gives the Minister the discretion to determine if applicants “have the required skills, profile, qualities, talents and expertise” so as to be in a position to make an important contribution to Malta’s national interest. The open-ended test allows for case-by-case determinations, though it also refers to the requirement of checks and balances in the determination process.
Enhanced Evaluation Process and Follow-up
From Recommendation to Advisory
One of the most significant amendments in the Malta Citizenship by Merit 2025 bill is the shift from an advisory to a recommendation assessment system. The Community Malta Agency (CMA) is now legally obliged to recommend whether citizenship is to be granted, and not merely offer an opinion.
Multi-Tiered Due Diligence
The board of evaluation, which consists of individuals of “sufficient experience and standing,” is obliged to:
- Ask recommendations from sectoral authorities.
- Hold applicant interviews.
- Guarantee consistency of applications with national priorities over the long term.
This multi-layered process allows the final ministerial decision to be guided by sector-specific expertise and organized due diligence.
Darmanin highlights:
The fact that there are sectoral-specific endorsements and a multi-layered due diligence process in place demonstrates a more advanced assessment mechanism, with a focus on specific merit and alignment with national priorities.
Ministerial Power with Procedural Safeguards
Article 10A retains the Minister’s ultimate discretion but mandates formal consideration of the board’s advice. This balances executive discretion and procedural protections.
Elimination of Preset Financial Thresholds under Malta Citizenship by Merit 2025
A Structural Shift Away from Financial Transaction Models
One of the most defining elements of the Malta Citizenship by Merit 2025 framework is its deliberate removal of predetermined financial contribution levels. Legal Notice 159 of 2025 formally abolishes all fixed monetary requirements that previously characterised MEIN, including:
Statutory donation benchmarks
Investment-linked contribution thresholds
Any reference to commercial or transactional acquisition of citizenship
As emphasised by Minister Byron Camilleri, “There is no predetermined sum one will pay to acquire Maltese citizenship.” This position reinforces Malta’s intention to transition decisively from investment-based acquisition toward a merit-driven model grounded in demonstrable national value.
A Merit-Focused Contribution Standard
Under Malta Citizenship by Merit 2025, applicants must now show tangible or intangible contributions such as scientific innovation, long-term philanthropic engagement, cultural impact, or technological advancement. Eligibility is therefore tied to the applicant’s substantive achievements and alignment with Malta’s national interest, not financial capacity.
Consequences for Applicants, Advisors, and Structuring
The removal of financial thresholds means that applicants and counsel must build applications around strategic demonstrations of merit, contribution, and alignment with Vision 2050. This includes sustainable development initiatives, technological transformation projects, or social-impact commitments that support Malta’s long-term national strategy.
Additionally, the Malta Citizenship by Merit 2025 system excludes private licensed agents from the application process. While the Community Malta Agency continues to administer applications, the absence of intermediaries furthers the government’s aim to eliminate any perception of commercialised or transactional citizenship.
Introduction of a Formal Appeals Mechanism under Malta Citizenship by Merit 2025
Citizenship Regulator
Article 25A provides for a new complaints process to be overseen by the Citizenship Regulator. There could be formal complaints by applicants regarding procedural error in the application process.
This brings in transparency and accountability, resolving previous criticism that applicants had no appeal on issues of procedural dispute.
Political Process and Consensus
Rushed Through Parliament
The Malta Citizenship by Merit 2025 bill was rushed through with unprecedented speed:
- First reading: June 30, 2025
- Second reading: July 23, 2025
- Committee stage: Same sitting, debated clause per clause live on television
The shortened process mirrored the urgency of bringing Maltese legislation into line with EU pressures prior to the summer recess.
Cross-Party Agreement
Both the ruling Labour Party and the opposition Nationalist Party supported the reforms. Although the Nationalists argued the President should have the ultimate decision, Minister Camilleri responded that this would politicize an apolitical role.
Opposition amendments to explicitly exclude “commercial elements” were rejected, with lawyers highlighting the need for positive, forward-looking legislation.
Transition Provisions
Outstanding Applications
The government explained:
- Outstanding MEIN applications will not be migrated to the new CBM scheme.
- Previously granted citizenship remains valid under the terms of the law when it was approved.
- Names of successful applicants will, nevertheless, continue to be published in the interests of transparency.
This tidy distinction between the two regimes promotes legal certainty while augmenting Malta’s international reputation.
Legal and Economic Context of Malta Citizenship by Merit 2025
EU Compliance
The reforms follow the 2025 ruling of the European Court of Justice in European Commission v. Republic of Malta (C-181/23) that found investment-based citizenship to be incompatible with EU values. By transitioning to merit-based citizenship, Malta preemptively sidesteps sanctions and demonstrates its commitment to EU norms.
National Strategy: Vision 2050
By putting talent, innovation, and contribution first, Malta is aligning its citizenship policy with national long-term goals, such as:
- Economic diversification beyond finance and gaming
- Technological advancement and digitalisation
- Global exposure and cultural diplomacy
This renders Malta a European country fostering value-driven migration policies.
Malta Residence Programmes vs Citizenship by Merit 2025
As citizenship legislation continues to change, residence options continue to appeal to expatriates and investors. Malta has two flagship programmes:
1. Malta Permanent Residence Programme (MPRP)
- Grants permanent residence with the right to live, work, and study.
- Includes a government and property investment obligation.
- Offers visa-free travel within the Schengen Area.
2. Malta Global Residence Programme (GRP)
- Grants tax residence with beneficial regulations for non-domiciled persons.
- Popular among ultra-high-net-worth families seeking beneficial tax planning.
These residency programmes run in parallel with the new Malta Citizenship by Merit 2025 paradigm to ensure Malta’s competitiveness in the investment migration and global mobility sector.
For further reading, see this comprehensive 2025 guide on Malta Citizenship by Merit.
Industry and Stakeholder Reactions
The reforms have drawn mixed but largely positive responses from market participants:
- Legal professionals view the systematic evaluation process credibility-enhancing.
- Advisers cite challenge of evidencing non-financial contributions.
- Reforms are viewed by international onlookers as a compromise needed to ensure EU compliance without Europe relinquishing its competitive advantage.
For a wider perspective, see Millionaire Migration 2025: The World’s Affluent Are on the Move, which places Malta’s reforms within the global wealth migration trend.
Conclusion: Malta Citizenship by Merit 2025 Marks the End of CBI and the Dawn of Merit-Based Citizenship
The expedited legislative approval of the Malta Citizenship by Merit 2025 Bill signals a paradigm shift in Malta’s immigration environment. Through the elimination of financial thresholds, widening of eligibility classes, and strengthening of due diligence, Malta once again positions itself as an innovator in the European values-based citizenship space.
While this marks the end of an era for citizenship by investment, it opens a new chapter where merit, talent, and contribution seal Maltese citizenship. Coupled with robust residence programmes, Malta continues to be a gateway for global investors and skilled individuals to the EU—on terms that balance national interest, EU compliance, and international reputation.
