Malta’s WRO Reform Explained: Key Questions On Updated Conditions Of Work

Malta’s reform of Wage Regulation Orders (WROs) marks a significant step towards modernising sector-specific employment rules. Now redesignated as Conditions of Work Regulation Orders, the reform aims to simplify existing frameworks, align entitlements across sectors, and provide greater clarity for both employers and employees.

Below, we address the key questions arising from the reform, focusing on its purpose, core principles, and the main changes introduced.

Background and Purpose

Q: What is a Conditions of Work Regulation Order?
A: A Conditions of Work Regulation Order is a set of legal rules that provides the minimum conditions of work which must apply in a particular job sector. Traditionally these were known as Wage Regulation Orders (WRO’s) or Wages Council Wage Regulation Orders and were prepared by a works council appointed by the government. The works council was composed of representatives of the sector being regulated, with the WRO’s dating back to the 1950s. Nowadays, since the works councils are no longer in existence, the titles were all changed. The new regulations will come into force later on this year.

Q: What is the WRO reform about in simple terms?
A: It modernises Malta’s sector-specific employment rules by redesignating Wage Regulation Orders as Conditions of Work Regulation Orders and—among other changes—introduces clearer, more consistent leave entitlements across sectors.

Q: What problem was the reform trying to fix?
A: Historically, leave rules differed between sectors under different WROs, creating uncertainty, administrative complexity, and sometimes unequal treatment between workers.

Harmonisation (Consistency Across Sectors)

Q: What does “harmonisation” mean in this context?
A: It means making Conditions of Work consistent across sectors, aligning them with general national employment rules, while keeping sector-specific rules only where genuinely necessary.

Q: What is the key benefit of harmonisation for employers?
A: It reduces complexity: employers can apply clearer, more uniform rules and lower the risk of accidental non-compliance.

Q: What is the key benefit of harmonisation for employees?
A: It increases predictability and fairness meaning that employees receive more consistent treatment across sectors and clearer entitlements.

Sick Leave (Day-One Right)

Q: What was the sick leave position before the reform in some sectors?
A: In some WROs, employees were only entitled to paid sick leave after completing a minimum service period (often six months or one year), leaving new employees potentially without paid sick leave early on in their employment.

Q: What is the main sick leave change introduced by the reform?
A: Sick leave applies from the first day of employment in all sectors regulated by a Conditions of Work Regulation Order.

Q: Can employees use their full annual sick leave entitlement immediately?
A: Yes. The reform makes it clear that employees can use the full sick leave entitlement for that year as from the beginning of the year (i.e. there is no accrual of sick leave as in the case of annual leave).

Q: What happens if an employee starts mid-year—do they still get the full sick leave quota?
A: The total annual sick leave entitlement is pro-rated if employment starts part way through the year, but the pro-rated balance may still be used upfront.

Annual Leave (National Standard)

Q: What is the reform’s approach to annual leave?
A: The new WROs provide that annual leave is governed strictly by the Organisation of Working Time Regulations. This eliminates any inconsistencies between different sectors.

Bereavement and Marriage Leave (Uniform Baseline)

Q: What were the disparities before the reform for workers not covered by a WRO?
A: Workers not covered by a WRO typically had 1 day bereavement leave and 2 days marriage leave, while many WROs provided more generous entitlements.

Q: What is the new baseline entitlement for bereavement and marriage leave?
A: The reform establishes a uniform baseline of:
• 3 days bereavement leave
• 3 days marriage leave

Q: Does the new baseline apply across all sectors?
A: Yes—regardless of sector, and regardless of whether the employee falls under a Conditions of Work Regulation Order.

Q: Were any restrictive conditions removed in relation to marriage leave?
A: Yes. Certain sector-specific rules requiring employees to remain in employment for a minimum period after marriage to retain the entitlement were entirely removed.

Minimum Wage Reform

Q: What change does the WRO reform introduce regarding minimum wages for minors?
A: The reform proposes the abolition of lower minimum wages for minors, providing that all workers falling under a Conditions of Work Regulation Order are entitled to the same minimum wage irrespective of age.

Q: How does the reform address differences in working hours when setting the minimum wage?
A: The minimum wage under the reformed regulations will be adjusted to reflect different working weeks, including 48 hour, 52 hour and 60 hour work weeks, depending on the sector concerned.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.