Malta’s Citizenship by Merit: From Investment-Based Naturalisation to a Merit-Based Route

Malta’s citizenship framework has recently undergone a significant change. For many years, international attention focused on Malta’s investor citizenship routes, first through the Individual Investor Programme and later through the framework for citizenship by naturalisation for exceptional services by direct investment.

That landscape has now changed. Malta has moved away from a model associated with fixed financial contributions and investment requirements, and towards a more discretionary, merit-based naturalisation framework.

The current route is known as Citizenship by Naturalisation on the Basis of Merit.

From IIP to Exceptional Services by Direct Investment

Malta’s earlier citizenship-by-investment model was the Individual Investor Programme, commonly known as the IIP. It was followed by the 2020 framework for Maltese Citizenship by Naturalisation for Exceptional Services by Direct Investment, often referred to as MEIN or ESDI.

These earlier routes were investment-led. They were structured around statutory financial contributions, property requirements, residence requirements and due diligence. They attracted substantial international interest, particularly from high-net-worth individuals seeking a connection with Malta and, through Malta, the European Union. However, the investment-based model also attracted legal and political scrutiny at European level.

The European Court of Justice and the End of the Old Model

In April 2025, the Court of Justice of the European Union delivered judgment in Commission v Malta, concerning Malta’s investor citizenship framework. The Court held that a system granting nationality in return for predetermined payments or investments was contrary to EU law.

Following that development, Malta amended its citizenship framework. Community Malta Agency described the amendments as addressing the CJEU decision, and Legal Notice 159 of 2025 amended the relevant subsidiary legislation.

The result is a new legal framework centred on merit rather than direct investment.

The Current Framework: Citizenship by Naturalisation on the Basis of Merit

The current regulations are titled the Granting of Citizenship by Naturalisation on the basis of Merit Regulations, S.L. 188.06. Their stated purpose is to regulate citizenship by naturalisation on the basis of merit under article 10(9) of the Maltese Citizenship Act.

This is not a rebranded investment programme. It is a discretionary naturalisation route for individuals whose profile, achievements or proposed contribution may justify Maltese citizenship on merit-based grounds.

Under the regulations, a person may qualify where he or she:

• renders exceptional service to Malta or to humanity;
• makes an exceptional contribution to Malta or to humanity; or
• is of exceptional interest to Malta.
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This marks the central difference from the previous model. The focus is no longer on a prescribed financial formula. The focus is now on exceptional value, reputation, contribution and Malta’s national interest.

The Old Direct Investment Provisions Have Been Deleted

The amended regulations expressly delete the former Part IV provisions dealing with naturalisation for exceptional services by direct investment. The previous provisions dealing with processing, requisites, oath, first five years, maximum admissions, and the former non-refundable fees and investment requirements were removed by Legal Notice 159 of 2025.

This is important for potential applicants. A person cannot approach the current framework as though it were the old investment route. There is no longer a simple “contribution plus property” pathway to citizenship.

How the New Process Works

The process now begins with a proposal letter. The applicant must submit a comprehensive proposal to the Evaluation Board through the Agency. This proposal must introduce the applicant, provide an overview of achievements, describe the exceptional service or contribution proposed, or explain why the applicant should be considered of exceptional interest to Malta. It must also include a plan showing how the applicant intends to continue contributing to Malta after naturalisation, should the application be successful.

Only applicants who receive a letter of approval in principle may proceed to submit a formal application for naturalisation on the basis of merit.

At application stage, the applicant must provide, among other things, proof of at least eight months’ residence in Malta before the application, proof of title to adequate residential property in Malta where applicable, confirmation of adequate knowledge of Maltese or English, and proof of ties created with Malta as proposed in the original proposal letter.

Due Diligence Remains Central

The new route is not simply an honours-based process. It remains subject to rigorous scrutiny.

The regulations provide for due diligence controls, including checks by third parties and internationally recognised specialised due diligence service providers. The controls are to be of a four-tier nature or more and may include security checks, anti-money laundering checks, terrorism financing checks, background verification and risk assessment.

The regulations also contain detailed disqualification grounds. These include matters relating to national security, public policy, public health, Interpol or Europol listing, serious criminality, terrorism, money laundering, crimes against humanity, war crimes, and conduct that may cause disrepute to Malta.

Ministerial Discretion

Citizenship by Merit remains highly discretionary. The Evaluation Board assesses the proposal and application, the Agency submits recommendations, and the Minister makes the final decision. The regulations state that the Minister is not obliged to provide reasons for the decision, and that the decision is final.

For applicants, this means that a strong legal submission is essential. The application must be credible, well-documented and aligned with Malta’s interests.

Continuing Obligations and Risk of Deprivation

The grant of citizenship may also carry continuing obligations. Before taking the oath of allegiance, the applicant must confirm in writing that he or she will continue to observe and fulfil the relevant commitments and obligations. The Agency may monitor these commitments and request proof of compliance.

The regulations also provide for deprivation of citizenship where a person fails to comply with material obligations or commitments, becomes a threat to national security, or acts in a manner seriously prejudicial to Malta’s interests.

What This Means for Prospective Applicants

The new Maltese Citizenship by Merit route is not suitable for every applicant. It is designed for individuals who can demonstrate exceptional achievement, exceptional contribution, or a compelling reason why their naturalisation would be of exceptional interest to Malta.

Potential candidates may include leading entrepreneurs, innovators, philanthropists, researchers, cultural figures, sports personalities, investors with a genuine strategic contribution, or individuals whose work carries measurable value for Malta or humanity.

The strongest applications will be those supported by independent evidence, a credible Malta-facing contribution plan, clear personal and professional reputation, clean due diligence, and a genuine connection with Malta.



How ARK Associates Can Assist

ARK Associates assists clients in assessing whether Citizenship by Naturalisation on the Basis of Merit may be an appropriate route in their circumstances.

Our work includes preliminary eligibility assessment, strategic case positioning, preparation of the proposal letter, supporting documentation, due diligence preparation, liaison with relevant authorities and guidance on Malta residence, property and continuing obligations.

This is a selective, discretionary and evidence-driven process. It requires careful preparation, legal clarity and a compelling narrative of merit.

For individuals whose achievements and proposed contribution align with Malta’s national interest, the new Citizenship by Merit route may represent an important opportunity to establish a lasting bond with Malta.