Malta Citizenship by Merit
Maltese citizenship may be acquired by descent, by birth, by registration, by ordinary naturalisation following long-term residence, or by naturalisation based on merit. This page sets out the framework that applies to the merit-based route, the documentation and procedural requirements that govern an application, and the considerations clients should be aware of before instructing counsel on whether this is the appropriate pathway.
The Legislative Framework
Citizenship by Naturalisation Based on Merit is governed by Subsidiary Legislation 188.06, made under the Maltese Citizenship Act (Chapter 188 of the Laws of Malta), as amended by Legal Notice 159 of 2025.
The merit-based framework as it now stands is the regime introduced following the April 2025 judgment of the Court of Justice of the European Union, which held that Malta’s earlier investor-based naturalisation route was incompatible with EU law, because of its transactional nature. The framework set out in SL 188.06, as amended by LN 159 of 2025, establishes a distinct legal basis grounded in substantive contribution rather than financial investment.
The route is administered by Community Malta Agency, which receives applications, refers Proposal Letters to the Evaluation Board for assessment, and submits recommendations to the Minister for determination.
The Five Recognised Categories
SL 188.06 recognises five categories of individuals whose achievements and ongoing engagement may qualify them for consideration under the merit-based framework. The categories are intentionally broad; what they share is a requirement for the contribution to be demonstrably exceptional and material to Malta or to humanity at large.
Scientists and researchers
Individuals whose research, discoveries or scientific work has materially advanced their field, with recognition through peer-reviewed publication, professional accolades, or institutional appointment, and whose continued engagement with Malta or the international scientific community demonstrates an ongoing contribution.
Athletes and sport persons
Sporting achievement at the highest competitive levels, supported by documented results, federation recognition, and a credible plan for continued engagement with Maltese sport or with sporting development more broadly.
Artists and cultural performers
Demonstrable achievement in the arts, including the visual arts, performing arts, literature, music or other recognised cultural fields, with substantive recognition and a basis for continued artistic engagement that benefits Malta or contributes to the wider cultural sphere.
Entrepreneurs and technologists
Individuals whose entrepreneurial or technological contribution has had a material and evidenced impact, whether through innovation, the creation of significant enterprise, or technological advancement, with a forward-looking plan for ongoing engagement with Malta.
Philanthropists
Individuals whose philanthropic contribution to Malta or to humanity at large is substantive, evidenced, and demonstrably beyond ordinary charitable engagement. The contribution must be material in scale and verifiable, not merely declarative.
In each case, ordinary professional accomplishment, however distinguished, will not satisfy the threshold. The legislation contemplates a contribution that is exceptional, and the Evaluation Board’s assessment turns on whether the applicant’s record and forward-looking plan substantiate that standard.
Understanding the Process
What distinguishes Citizenship by Naturalisation Based on Merit is its focus on the exceptional contribution or service rendered to Malta or to humanity at large. The framework is designed for individuals whose achievements – whether past, ongoing, or planned – reflect a genuine and demonstrable benefit to society.
The process is sequential in nature. Many applicants approach this route without fully appreciating that each step carries its own documentation requirements, dependencies, and institutional decision-makers. Proceeding out of order, or running steps concurrently, is among the most common and costly mistakes in this type of application. Each step must be formally completed before the next may begin.
Submission of the Proposal Letter
Under Article 11A(1) of Subsidiary Legislation 188.06, the process begins with the submission of a detailed Proposal Letter to Community Malta Agency. This is not a biographical summary – it is a structured and substantiated argument that must address three core elements.
Applicants may include their dependants as stipulated in the legislation. The Proposal Letter and supporting documentation are submitted to the Agency and referred to the Evaluation Board for assessment.
Background and achievements
A clear, evidenced account of the applicant’s professional, scientific, cultural, athletic, entrepreneurial or philanthropic achievements, appropriately contextualised. The assessment considers not only past accomplishments but also the applicant’s capacity and intention to continue contributing in the future.
Exceptional contribution or service
A rigorous articulation of how the applicant’s activities have served Malta or humanity at large. Ordinary professional accomplishment, however distinguished, will not satisfy this threshold. The contribution must be demonstrably material and evidenced, not merely asserted.
Forward-looking plan
A credible and concrete plan for continued engagement with Malta following naturalisation. This reflects the regulatory expectation that citizenship by merit is an investment in an ongoing relationship, not merely a recognition of past achievement.
Due Diligence and Eligibility Documentation
Alongside the Proposal Letter, the applicant is required to prepare a comprehensive documentary dossier in accordance with Subsidiary Legislation 188.06. This covers:
- Full personal and family details
- Complete education and employment history
- Medical certification confirming the applicant’s health status
- Full financial disclosure, including source of wealth and source of funds
- Particulars of all business interests, directorships, and significant shareholdings
- Signed declarations confirming the accuracy and completeness of all information provided
The due diligence applied to merit applications is multi-tier and enhanced. Applicants should anticipate adverse media screening, checks against international sanctions lists, and detailed verification of source of wealth through supporting financial documentation.
Evaluation, Ministerial Determination and Finality of Approval
Once the Board has concluded its evaluation, its recommendation is submitted to the Agency and referred to the Minister for a final determination. The Minister considers the recommendation and issues a decision granting or withholding approval in principle. This decision is entirely at the Minister’s discretion, no reasons are required to be given, and the decision is final.
This is a defining feature of the merit-based framework and one that distinguishes it sharply from programmes that publish objective qualifying criteria. Applicants and their advisers must approach the route with that understanding from the outset.
How Citizenship by Merit Compares to Other Maltese Citizenship and Residence Routes
The table below sets out the high-level distinction between the main Maltese routes most relevant to international clients considering Maltese citizenship or long-term residence. It is intended as an orientation aid; the appropriate route in any given case depends on the applicant’s circumstances, objectives and the documentation available.
The choice between routes is not a question of comparison alone. Citizenship by Merit is appropriate for individuals whose record substantiates an exceptional standard of contribution. For applicants whose circumstances do not meet that threshold, other routes – including ordinary naturalisation following residence, the MPRP, or the GRP – may be more appropriate depending on the objective.
Citizenship by Merit
Status conferred: Maltese citizenship
Basis for grant: Exceptional contribution or service
Governing law: SL 188.06 as amended by LN 159/2025
Financial threshold: None as such
Decision basis: Discretionary, final
Naturalisation (ordinary)
Status conferred: Maltese citizenship
Basis for grant: Long-term residence and qualifying criteria
Governing law: Maltese Citizenship Act (Chp. 188)
Financial threshold: None
Decision basis: Criteria-based
MPRP
Status conferred: Permanent residence
Basis for grant: Investment, property and due diligence
Governing law: MPRP Regulations SL 217.26
Financial threshold: Defined contribution and property
Decision basis: Criteria-based
GRP
Status conferred: Preferential tax rate
Basis for grant: Property, tax and due diligence
Governing law: SL 123.148
Financial threshold: Property and minimum EUR 15k annual tax
Decision basis: Criteria-based
How We Help
GVZH Advocates advises clients considering whether Citizenship by Naturalisation Based on Merit is the appropriate route, and supports those who proceed through the formal stages set out under SL 188.06.
Initial assessment
We begin with an honest evaluation of whether the applicant’s record substantiates the exceptional contribution threshold contemplated by the legislation. This is conducted before any preparatory work begins. Where the threshold is unlikely to be met, we say so, and advise on whether an alternative pathway – ordinary naturalisation following residence, the MPRP, or the GRP – better suits the client’s objectives.
Preparation of the Proposal Letter
Where the merit-based route is the appropriate path, we work with the client to prepare a Proposal Letter with the rigour and substantiation the framework requires. This typically involves the assembly of evidential material across the client’s record, the development of the forward-looking plan, and the structured articulation of the exceptional contribution itself.
Documentary dossier and due diligence
We coordinate the preparation of the full documentary dossier required under SL 188.06, including personal, financial, business and source-of-wealth materials, and manage the legalisation and translation of documents originating outside Malta. Our work anticipates the multi-tier due diligence applied to merit applications, including adverse media screening and sanctions checks.
Engagement with Community Malta Agency
We act as the client’s interface with the Agency throughout the formal stages, manage correspondence, and respond to any requests for additional information during the Evaluation Board’s assessment.
Wider relocation and tax considerations
Citizenship is one element of a wider relationship with Malta. We coordinate, through a single point of contact, on the residence, tax services & advisory, corporate and employment considerations that typically accompany the merit-based route – including any prior or contemporaneous residence under the GRP, the MPRP or another route, and the corporate and tax structuring appropriate to the client’s situation.
Frequently Asked Questions (FAQs)
Is your question unanswered? Speak with Ann Bugeja directly: privateclients@gvzh.mt
What is Citizenship by Merit?
Citizenship by Naturalisation Based on Merit is the route to Maltese citizenship for individuals whose exceptional contribution or service to Malta, or to humanity at large, warrants the conferral of citizenship. It is governed by Subsidiary Legislation 188.06, as amended by Legal Notice 159 of 2025, and administered by Community Malta Agency.
How does Citizenship by Merit differ from the former MEIN programme?
The previous Citizenship by Investment framework was held by the Court of Justice of the European Union in April 2025 to be incompatible with EU law. The merit-based framework under Legal Notice 159 of 2025 establishes a distinct legal basis grounded in substantive contribution rather than financial investment. There is no fixed contribution amount, and there is no pathway based on financial threshold alone.
Who can apply?
The legislation recognises five categories: scientists and researchers, athletes and sport persons, artists and cultural performers, entrepreneurs and technologists, and philanthropists. In each case, the applicant must demonstrate an exceptional contribution that is material to Malta or to humanity at large. Ordinary professional accomplishment, however distinguished, will not satisfy the threshold.
Is there a financial contribution?
There is no fixed contribution amount and no qualifying threshold based on capital alone. The framework is designed to reward substantive, evidenced contribution. Where applicants have made philanthropic contributions, those may form part of the record that supports the application, but financial contribution is not, on its own, a basis for the grant of citizenship under this route.
Can dependants be included?
Yes. Applicants may include dependants as stipulated in the legislation. The conditions and definitions governing dependants follow the relevant provisions of SL 188.06; we advise on these in detail at the outset of any engagement.
How long does the process take?
The process unfolds across distinct sequential stages – the Proposal Letter and supporting dossier, the Evaluation Board’s assessment, the Agency’s referral, and the Ministerial determination. The duration of each stage depends on the completeness of the documentation, the volume of work before the relevant institutions, and the complexity of the applicant’s record. Because the route is discretionary and final, and because Community Malta Agency does not publish standardised timelines, we do not provide timeline commitments. We can give clients an informed indication of what to expect based on the circumstances of their application.
Can the Ministerial decision be appealed?
The Minister’s decision is at the Minister’s discretion, no reasons are required to be given, and the decision is final. This is a defining feature of the merit-based framework and one that distinguishes it from programmes with published objective criteria.
What due diligence is applied?
The due diligence applied to merit applications is multi-tier and enhanced. Applicants should anticipate adverse media screening, checks against international sanctions lists, and detailed verification of source of wealth through supporting financial documentation. Full personal, financial and business disclosure is required as part of the documentary dossier.
How does Citizenship by Merit compare to MPRP or GRP?
The MPRP confers permanent residence; the GRP confers residence with a special tax status; Citizenship by Merit confers Maltese citizenship. The three are different statuses with different legal bases and different criteria. The merit-based route is appropriate only where the applicant’s record substantiates the exceptional contribution standard. The MPRP and GRP follow defined criteria-based frameworks and may be more suitable where the objective is residence rather than citizenship.
What if my application is unsuccessful?
The Minister’s decision is final and no reasons are required to be given.
What does the GVZH Citizenship by Merit service include?
We advise on whether the merit-based route is the appropriate pathway in light of the applicant’s record; on the preparation of the Proposal Letter and supporting documentary dossier; on the coordination of the multi-tier due diligence; on engagement with Community Malta Agency throughout the formal stages; and on the wider relocation, residence, tax and corporate considerations that typically accompany the merit-based route.
Related Services
Practice Lead
Ann Bugeja, Partner
Ann Bugeja leads GVZH Advocates’ Immigration, Citizenship & Residence practice. She advises individuals, families and family offices on the full range of Maltese residence and citizenship routes, with a focus on private clients with cross-border tax and corporate considerations. She is regularly consulted on the structuring of multi-jurisdictional relocations and on the interaction between Maltese residence programmes and the tax regimes of source jurisdictions.
For a confidential introductory call about Citizenship by Merit or any other Maltese citizenship or residence route, contact Ann at privateclients@gvzh.mt.
Published: July 2026 · Last reviewed: July 2026
Disclaimer: This page provides general information only and does not constitute legal advice. The applicable legislation and procedures are accurate as at the date of last review but may be subject to change. Specific advice should be sought on individual circumstances. The Ministerial determination on any application is discretionary and final.
