Overview Of The Updated Application And Supervisory Fees In Financial Market, Investment Services, Insurance And More!

The 2024 overhaul of Malta's financial regulations marks a transformative moment for the country's investment, insurance, and financial markets. Namely, a new fee structure was introduced under the Investment Services Act (Chapter 370 of the Laws of Malta), Insurance Distribution Act (Chapter 487 of the Laws of Malta), Insurance Business Act (Chapter 403 of the Laws of Malta), Financial Markets Act (Chapter 345 of the Laws of Malta), Banking Act (Chapter 371 of the Laws of Malta) and Financial Institutions Act (Chapter 376 of the Laws of Malta), which is to take effect on January 1, 2025. By introducing incremental fee adjustments, applicable from 2025, the regulations promise to enhance compliance, whilst catering for the diverse needs of regulated entities across Malta's financial ecosystem.

1. Investment Services Act (Fees) Regulations, 2024

The recently published Investment Services Act (Fees) Regulations, 2024, introduces a revised fee structure for financial services entities operating under Malta's Investment Services Act, set to take effect on January 1, 2025. Key updates include a tiered system for application and supervisory fees based on the type of services provided, client base, and whether client assets are controlled. For instance, entities offering investment services only to professional clients without managing client funds will have different fee brackets compared to those providing comprehensive services. The regulations also detail specific fee adjustments for collective investment schemes, administrative services, tied agents, and alternative investment fund managers ("AIFMs"). Fee rates are scheduled to increase incrementally through 2029, with a new 25% fee reduction applicable for multiple service applications or modifications. The act repeals prior fee regulations while preserving liabilities for fees accrued under the old framework. These changes aim to streamline compliance costs while accommodating industry diversity.

Below is a breakdown of the updated fees:

Application Fees (First Schedule)

These fees are divided into categories based on the type of investment services and the nature of the collective investment schemes. The fees will be collected annually and gradually increase year over year.

Investment Services Providers

• Investment Services under Regulation 3(1) (a)-(e): The application fees for firms offering investment services (such as portfolio management, investment advice, and other services) increase yearly. The fees are categorized based on the type of service:
  • Services under regulation 3(1)(a) start at €3,500 in 2025, growing to €5,000 in 2027.
  • Services under regulation 3(1)(b) start at €4,000 and rise to €6,000 by 2027.
  • Services under regulation 3(1)(c) (which likely include market operations) start at €6,500 and increase to €8,000.
  • Services under regulation 3(1)(d), the most expensive category, which would cover large-scale investment activities, begin at €11,500, increasing to €19,000 by 2027.
  • Services under regulation 3(1)(e), potentially involving other specialized financial services, start at €6,000, growing to €7,500.

• Regulation 3(2) covers another specific group of service providers, with fees starting at €19,000 and increasing significantly to up to €26,500 over the years.

Collective Investment Schemes

• UCITS (Undertakings for Collective Investment in Transferable Securities) and Retail AIFs (Alternative Investment Funds):
  • Fund Application Fees: For third-party-managed funds, the fees start at €3,750 and are expected to reach €5,250 by 2027. Whereas, for self-managed funds, the fees are set at €5,000 and increase to €6,500.
  • Sub-Fund Application Fees: These are set at €1,000 for the first five sub-funds and €600 for every additional sub-fund.

• Professional Investor Funds ("PIFs"):
  • Fund Application Fees: Third-party-managed funds start at €2,250, rising to €3,750 by 2027. In comparison, self-managed funds start at €3,000, growing up to €4,500.
  • Sub-Fund Application Fees: The fees for the first five sub-funds are €750, and every additional sub-fund costs €315.

• Alternative Investment Funds ("AIFs"):
  • Similar to the PIFs, application fees for third-party-managed AIFs begin at €3,750 and increase to €5,250. Self-managed funds are more expensive, starting at €5,000 and growing to €6,500.

Sub-Fund Application Fees:

• First Five Sub-Funds: The fee for the first five sub-funds of any fund is €1,000 per sub-fund, with no change expected in the years 2025–2027.

• Additional Sub-Funds (Beyond Five): For any sub-fund beyond the first five, the application fee remains stable at €600 per sub-fund throughout 2025 and 2027.

Provision of Administrative Services:

• General Administrative Service Providers:
  • Fees for persons providing administrative services (excluding incorporated cell companies) are €4,500 in 2025, increasing to €11,000 by 2027.

• Recognized Incorporated Cell Companies:
  • The fee remains stable at €3,000 across the years 2025–2027.

Private Collective Investment Schemes:

• The application fee remains fixed at €2,000 per scheme across the years 2025–2027.

Tied Agents:

• Individuals: The application fee for individuals acting as tied agents is €300, with no change expected over the years.

• Non-Individuals (Companies, Partnerships, etc.): The application fee is €350 across the years 2025–2029.

• Notified AIFs (Alternative Investment Funds):
  • Fund Application Fee: For notified AIFs the fee starts at €2,250 in 2025, rising to €3,000 by 2027.
  • Sub-Fund Application Fee: The sub-fund application fee remains €750 across the years.

• Notified PIFs (Professional Investor Funds):
  • Fund Application Fee: The fee starts at €2,000 in 2025, increasing to €2,750 by 2027.
  • Sub-Fund Application Fee: The sub-fund application fee remains at €750 throughout 2025 and 2027.

European Investment Firms (Establishing Branches in Malta):

• Notification Fees for Different Investment Services:
  • Regulation 11(1)(a) (Investment services in the form of portfolio management): The fee is €750 annually.
  • Regulation 11(1)(b) (Investment advice): The fee is set at €1,000 annually.
  • Regulation 11(1)(c) (Execution of orders on behalf of clients): The fee is €1,650 annually.

European Management Companies and AIFMs (Branches in Malta):

• Notification Fees: Both European management companies and AIFMs setting up branches in Malta face a stable notification fee of €1,250 per year.

European UCITS (Undertakings for Collective Investment in Transferable Securities):

• Fund Notification Fee: The fee is marked at €2,500 per fund, with no expected changes for 2025–2027.
  • Sub-Fund Notification Fee: The fee is set at €450 per sub-fund, also remaining unchanged.

European AIFMs Marketing Units or Shares (Regulation 15(1)):

• Fund Notification Fee: The fee is set at €2,500 annually.

• Sub-Fund Notification Fee: The fee is €450 annually.

Maltese or European AIFMs Marketing Units or Shares (Regulation 15(5)):

• Fund Notification Fee: The fee is €2,500 annually.

• Sub-Fund Notification Fee: The fee is marked at €450 annually.

Third Country AIFMs Marketing Units or Shares (Regulation 15(8)):

• Fund Notification Fee: The fee is set at €2,500 annually.

• Sub-Fund Notification Fee: The fee is €450 annually.

2. Supervisory Fees:

For investment services provided under regulation (4)(1), the fees are structured based on net revenue and increase gradually over the years:

• Regulation (4)(1)(a) (Basic Investment Services):
  • Minimum Fee: The fee starts at €3,400 in 2025, reaching €6,000 by 2029.
  • Maximum Fee: The fee starts at €16,700 in 2025, reaching €19,300 by 2029.
  • Every additional €50,000 in Net Revenue is capped at €700.

• Regulation (4)(1)(b) (Investment Advice and Management):
  • Minimum Fee: The fee starts at €4,000 in 2025, reaching €7,000 by 2029.
  • Maximum Fee: The fee starts at €17,300 in 2025, reaching €20,300 by 2029.
  • Every Additional €50,000 in Net Revenue is capped at €700.

• Regulation (4)(1)(c) (Execution of Orders):
  • Minimum Fee: The fee starts at €6,500 in 2025, reaching €11,000 by 2029.
  • Maximum Fee: The fee starts at €19,800 in 2025, reaching €26,200 by 2029.
  • Every Additional €250,000 in Net Revenue thus incurs €700.

• Regulation (4)(1)(d) (Larger Investment Activities):
  • Minimum Fee: The fee starts at €15,000 in 2025, reaching €22,500 by 2029.
  • Maximum Fee: The fee starts at €28,300 in 2025, reaching €40,200 by 2029.
  • Every Additional €250,000 in Net Revenue incurs €700.

• Regulation (4)(1)(e) (Additional Services):
  • Minimum Fee: The fee starts at €6,000 in 2025, reaching €7,500 by 2029.

• Regulation (4)(4) (Complex Services):
  • Fees begin at €20,500 in 2025, reaching up to €36,000 by 2029 for each service type.

Collective Investment Schemes:

• UCITS and Retail AIFs:
  • Fund Supervisory Fees: If managed by a third party, the fee starts at €4,000 in 2025, growing to €8,500 by 2029. If it is a self-managed one, it starts at €6,000 in 2025, growing to €10,500 by 2029.
  • Sub-Fund Supervisory Fees: Fees increase from €650 to €800 over the years.

• Professional Investor Funds (PIFs):
  • Fund Supervisory Fees: If managed by a third party the fee is set at €3,000 in 2025, reaching €6,000 by 2029. In comparison the fee for self-managed ones starts at €4,000 in 2025, reaching €7,000 by 2029.
  • Sub-Fund Supervisory Fees: Fees remain steady at €650 reaching €700 in 2029.

• Alternative Investment Funds (AIFs):
  • Fund Supervisory Fees: When managed by a third party, the fee is €4,000 for 2025, reaching €8,000 by 2029. As per the self-managed ones, the sum starts at €6,000 in 2025, reaching €10,000 by 2029.
  • Sub-Fund Supervisory Fees: Increase from €650 to €800.

Provision of Administrative Services:

• General Administrative Service Providers: Fees range from €4,000 in 2025 to €11,000 in 2029.
• Recognized Incorporated Cell Companies: The fee ranges from €2,000 for 2025 and reaches €3,000 in 2029.

Private Collective Investment Schemes:

• Supervisory Fees: Start at €1,200 and increase to €1,600 by 2029.

Tied Agents:

• Individuals: Fees start at €400 and rise to €750 by 2029.
• Non-Individuals: Fees start at €450 and increase to €800 by 2029.

Notified AIFs and PIFs:

• Fund Supervisory Fees: Range from €2,500 to €4,500 over the years.
• Sub-Fund Supervisory Fees: Remain steady at €650–€700.

European Investment Firms (Branches in Malta):

• Regulation 11(1)(a):
  • Fees are set at €1,200 between 2025 and 2029.
• Regulation 11(1)(B):
  • Fees are set at €3,000 between 2025 and 2029.
• Regulation 11(1)(c):
  • Fees are set at €3,600 between 2025 and 2029.

European Management Companies (Branch):

• Fees are set at €4,000 and remain steady from 2025 until 2029.

EuropeanAIFMs (Branch):

• Fees are set at €4,000 and remain the same from 2025 until 2029.

European UCITS:

• Fund Supervisory Fees: Remain steady at €3,000 from 2025 until 2029.
• Sub-Fund Supervisory Fees: Also remain stable at €500 starting from 2025 until 2029.

European AIFMs Marketing Units or Shares (Regulation 15(1)):

• Fund Supervisory Fees: Range from €4,000 in 2025 to €6,000 in 2029.
• Sub-Fund Supervisory Fees: Remain steady at €500 from 2025 until 2029.

Maltese or European AIFMs Marketing Units or Shares (Regulation 15(5)):

• Fund Supervisory Fees: Remain steady at €3,000 from 2025 until 2029.
• Sub-Fund Supervisory Fees: Remain steady at €500 between 2025 and 2029.

Third Country AIFMs Marketing Units or Shares (Regulation 15(8)):

• Fund Supervisory Fees: Range from €3,000 in 2025 to €3,500 in 2029.
• Sub-Fund Supervisory Fees: The fees remain steady at €1,000 from 2025 until 2029.

Insurance Distribution Act (Fees) Regulations, 2024

The Insurance Distribution Act (Fees) Regulations, 2024, complements the changes introduced under the Investment Services Act by overhauling the fee framework for insurance and reinsurance distribution entities, within the Insurance Distribution Act, as effective January 1, 2025. This new regulation introduces tiered fees for application and supervision based on the type of intermediary, including agents, brokers, managers, tied intermediaries, and ancillary intermediaries. It also sets specific provisions for cell companies, their individual cells, and branches established by local or European intermediaries under passporting arrangements. Notable updates include the introduction of prorated initial supervisory fees, a 25% discount on fees for modifications involving additional services, and distinct charges for entities registering underwriting agreements or restoring their names to official registers. These regulations also repeal the previous fee structure while retaining accountability for fees accrued under the former regime.

Here is an overview of the new fees:

Application Fees:

• The registration of natural persons in the Agents Register, Managers Register, or Brokers Register ranges from €200 in 2025 to €300 in 2029.
• Enrolment of non-cell companies in the Agents List, Managers List, or Brokers List starts at €5,000 in 2025 and increases to €10,000 by 2029.
• Enrolment of cell companies in the Managers List or Brokers List varies, with fees for cell companies starting at €4,000 in 2025 and reaching €8,000 by 2029, while fees for cells range from €2,000 in 2025 to €3,000 in 2029.
• The establishment of a branch incurs fees from €700 in 2025, increasing to €1,400 in 2029.
• The enrolment fees for Tied and Ancillary Insurance Intermediaries Lists range from €360 in 2025 to €1,000 in 2029.

Ancillary Fees:

• New appointments for persons enrolled in the Agents List or Managers List range from €750 in 2025 to €1,500 by 2029.
• Underwriting agreement registration fees start at €400 in 2025 and increase to €600 in 2029.
• Name restoration in the Agents Registers or Brokers Registers ranges from €500 in 2025 to €4,000 in 2029.

Annual Supervisory Fees:

• For natural persons registered in the Agents Register, Managers Register, or Brokers Register, the fee ranges from €250 in 2025 to €400 in 2029.
• Cell companies in the Managers List face supervisory fees ranging from €2,200 in 2025 to €3,000 in 2029.
• Branch fees for local companies are between €700 in 2025 and €1,400 in 2029.
• Tied Insurance Intermediaries pay supervisory fees ranging from €350 in 2025 to €650 in 2029.
• For Ancillary Insurance Intermediaries, the supervisory fees range from €360 in 2025 to €600 in 2029.
• European intermediaries' supervisory fees start at €500 in 2025, increasing to €1,000 by 2029.

The Insurance Business Act (Fees) Regulations

The Insurance Business Act (Fees) Regulations, 2024, further updates Malta's financial regulatory framework by revising the fee structure for entities engaged in insurance and reinsurance activities, Effective January 1, 2025, it brings about changes under the Insurance Distribution Act. These regulations introduce distinct application and supervisory fees based on the type of entity, including local and third-country undertakings, captive insurers, and cell companies. For the first time, separate fee schedules apply to securitisation cell companies and reinsurance special purpose vehicles, reflecting their unique operational nature. The updates also include prorated initial supervisory fees, a 25% discount on fees for modifications involving additional insurance or reinsurance classes, and new charges for entities transferring business or creating cells. Repealing the prior framework, these regulations aim to provide clarity and align fees with the operational scale and complexity of insurance businesses, while retaining liabilities for fees accrued under the old system.

Here is an overview of the new fees:

Application Fee (2025-2029):

• Undertakings in Malta:
  • Long-term Business: €1,600 per class, with a minimum fee €15,000 in 2025, rising to €2,000 per class, with a minimum fee of €20,000 by 2027.
  • General Business: €1,000 per class, with a minimum fee of €10,000 in 2025, increasing to €1,500 per class, with a minimum fee of €15,000 by 2027.

• Third-country Insurance/ Reinsurance Undertakings:
  • Long-term Business: €800 per class, with a minimum fee of €8,000 in 2025, increasing to €1,000, with a minimum fee of €10,000 by 2027.
  • General Business: €500 per class, with a minimum fee of €7,000 in 2025, rising to €750, with a minimum fee of €9,000 by 2027.

• Captive Insurance/ Reinsurance Undertakings:
  • Long-term Business: €800, with a minimum fee of €9,000 per class, in 2025, rising to €1,000, with a minimum fee of 10,000 per class by 2027.
  • General Business: €500, with a minimum fee of €7,000 per class in 2025, rising to €750 with a minimum fee of €9,000 by 2027.

• Cell Companies and Incorporated Cell Companies:
  • Long-term Business Costs range from €1,600, with a minimum fee of €15,000 to €2,000, with a minimum fee of €20,000 per class by 2027.

• General Business: The fee is €1,000, with a minimum fee of €10,000 per class in 2025, increasing to €1,500, with a minimum fee of €15,000 per class by 2027.

Creation of an Incorporated Cell:

• Long-term Business: The fee starts at €800 per class in 2025, with a minimum fee of €5,000 increasing to €1,000, with a minimum fee of €10,000 per class by 2027.
• General Business: The fee is set at €500, with a minimum fee of €4,000 per class in 2025, rising to €900, with a minimum fee of €9,000 per class by 2027.

Transformation from or to an Incorporated Cell Company:

• Long-term Business: The fee starts at €1,600, with a minimum fee of €15,000 per class in 2025, increasing to €2,000 with a minimum fee of €20,000 per class by 2027.
• General Business: The fee starts at €1,000, with a minimum fee of €10,000 per class in 2025, increasing to €1,500, with a minimum fee of €15,000 per class by 2027.

Other Fees (2025-2029):

• Establishment of a Branch: The fee starts at €700 in 2025, rising to €1,400 by 2027.
• Reinsurance Special Purpose Vehicle: The fee stays €2,500 annually, remaining unchanged from 2025 until 2029.
• Additional Risk: The fee remains €2,500 per contract, from 2025 until 2029.
• Securitisation Cell Companies: When carrying on Business as a Reinsurance Special Purpose Vehicle the fee remains €2,500 per contract; hence, stays unchanged from 2025 until 2029. For the creation of a Cell, the fee is €2,500 per cell throughout 2025 and 2029.
• Transfer of General Business: The minimum fee is marked at €5,000 in 2025, rising to €10,000 by 2027.
• Transfer of General or Long-term Business by an Insurance/Reinsurance Undertaking (Head Office Outside Malta): The fee is €7,000 in 2025, and rises to €12,000 by 2027.

Annual Supervisory Fee (2025–2027 and Beyond)

• Reinsurance Special Purpose Vehicle: The fee is marked at €8,000 annually and remains unchanged from 2025 until 2027.
• Securitisation Entities
• Securitisation Cell Company: The fee is stabilised at €6,000 annually, starting from 2025 until 2027.
• Securitisation Cell: The fee remains €3,500 annually, from 2025 until 2027.

• Approved Auditors: For an individual the sum from €400 for 2025, reaching €600 in 2027. In comparison, audit firms are required to pay a fee of €2,000 in 2025, which gradually reaches €6,000 in 2027.
• Branch: The fee starts at €700 in 2025 and reaches €1,400 in 2027.
• Undertakings with Head Office in Malta (Insurance Business) – The minimum fee starts from €4,500 in 2025, up to €7,500 in 2027 and beyond.
• Gross Premium Brackets

• Up to and including €1 million: Same as the minimum fee.
• From €1M up to €2.5M: starting from €9,000 in 2025, reaching €12,000 in 2027.
• From €2.5M up to €3.5M: starting from €10,500 in 2025, reaching €14,500 in 2027.
• From €3.5M up to €5M: starting from €12,500 in 2025, reaching €16,500 in 2027.
• From €5M up to €7.5M: starting from €17,000 in 2025, reaching €23,000 in 2027.
• From €7.5M up to €12M: starting from €22,000 in 2025, reaching €30,000 in 2027.
• From €12M up to €25M: starting from €25,000 in 2025, reaching €35,500 in 2027.
• From €25M up to €35M: starting from €32,000 in 2025, reaching €44,000 in 2027.
• From €35M up to €50M: starting from €35,000 in 2025, reaching €47,000 in 2027.
• From €50M up to €70M: starting from €45,000 in 2025, reaching €55,000 in 2027.
• From €70M up to €100M: starting from €47,000 in 2025, reaching €59,000 in 2027.
• From €100M up to €150M: starting from €52,000 in 2025, reaching €70,000 in 2027.
• From €150M: €60,500 in 2025, reaching €81,500 in 2027.

• European Insurance Undertakings: The minimum fee starts at €7,000 in 2025, reaching €8,500 in 2027.
• Gross Premium Brackets

• Up to and including €2.5 million: Same as the minimum fee.
• From €2.5M up to €3.5M: starting from €8,000 in 2025, reaching €9,500 in 2027.
• From €3.5M up to €5M: starting from €9,500 in 2025, reaching €11,500 in 2027.
• From €5M up to €7.5M: starting from €12,500 in 2025, reaching €14,500 in 2027.
• From €7.5M up to €12M: starting from €14,000 in 2025, reaching €16,000 in 2027.
• From €12M up to €25M: starting from €18,000 (2025), reaching €24,000 in 2027.
• Over €25M: starting from €26,000 in 2025, reaching €28,000 in 2027.

4. Financial Markets (Fees) Regulations, 2024

The newly issued Financial Markets (Fees) Regulations, 2024 apply to the Investment Services Act and the Financial Markets Act. These regulations introduce a tiered fee structure for applications and annual supervisory obligations for regulated markets, central securities depositories ("CSDs"), multilateral trading facilities ("MTFs"), and organized trading facilities ("OTFs"), with rates varying by market capitalization. For entities seeking multiple licenses or authorizations, the framework provides financial incentives, including a 25% discount on additional application fees and a 75% reduction in annual supervisory fees for secondary licenses. Notably, specific provisions address prorated fees for newly licensed entities within their first year. A detailed schedule sets fees for approving prospectuses and securities listings, including thresholds for equity, debt securities, and collective investment schemes. Importantly, these regulations repeal the previous Regulated Markets and Central Securities Depositories (Fees) Regulations but preserve liabilities incurred under the old framework, clarifying that fees are non-refundable and generally not prorated beyond specified cases.

The updates fees are the following:

First Schedule (regulations 3, 4, 5, 6, and 7) – Application Fee

• Regulated Market: The fees start from €45,000 in 2025, reaching €75,000 in 2027 and thereafter.
• Central Securities Depository: The fees from €19,000 in 2025, reaching €26,500 in 2027 and thereafter.
• Central Securities Depository (with banking-type ancillary services): The fees start from €49,000 in 2025, reaching €56,500 in 2027 and thereafter.
• Multilateral Trading Facility: The fees start from €37,500 in 2025, reaching €67,500 in 2027 and thereafter.
• Organised Trading Facility: The fees start from €37,500 in 2025, reaching €67,500 in 2027 and thereafter.

Second Schedule (regulations 3, 4, 5, 6 and 7) – Annual Supervisory Fee

• Regulated Market (Market Capitalisation from €nil to €5 billion): The fees start from €60,000 in 2025, reaching €100,000 in 2027 and thereafter.
• Regulated Market (Market Capitalisation over €5 billion up to €10 billion): The fees start from €80,000 in 2025, reaching €120,000 in 2027 and thereafter.
• Regulated Market (Market Capitalisation over €10 billion up to €25 billion): The fees start from €100,000 in 2025, reaching €140,000 in 2027 and thereafter.
• Regulated Market (Market Capitalisation over €25 billion up to €50 billion): The fees start from €120,000 in 2025, reaching €160,000 in 2027 and thereafter.
• Regulated Market (Market Capitalisation over €50 billion): The fees start from €140,000 in 2025, reaching €180,000 in 2027 and thereafter.
• Central Securities Depository: The fees start from €25,000 in 2025, reaching €35,000 in 2027 and thereafter.
• Central Securities Depository (with banking-type ancillary services): The fees start from €85,000 in 2025, reaching €95,000 in 2027 and thereafter.
• Multilateral Trading Facility (Market Capitalisation from €nil to €5 billion): The fees start from €50,000 in 2025, reaching €90,000 in 2027 and thereafter.
• Multilateral Trading Facility (Market Capitalisation over €5 billion up to €10 billion): The fees start from €70,000 in 2025, reaching €110,000 in 2027 and thereafter.

• Multilateral Trading Facility (Market Capitalisation over €10 billion up to €25 billion): The fees start from €90,000 in 2025, reaching €130,000 in 2027 and thereafter.
• Multilateral Trading Facility (Market Capitalisation over €25 billion up to €50 billion): Fees start from €110,000 in 2025, reaching €150,000 in 2027 and thereafter.
• Multilateral Trading Facility (Market Capitalisation over €50 billion): The fees start from €130,000 in 2025, reaching €170,000 in 2027 and thereafter.
• Organised Trading Facility (Market Capitalisation from €nil to €5 billion): The fees start from €50,000 in 2025, reaching €90,000 in 2027 and thereafter.
• Organised Trading Facility (Market Capitalisation over €5 billion up to €10 billion): The fees start from €70,000 in 2025, reaching €110,000 in 2027 and thereafter.
• Organised Trading Facility (Market Capitalisation over €10 billion up to €25 billion): The fees start from €90,000 in 2025, reaching €130,000 in 2027 and thereafter.
• Organised Trading Facility (Market Capitalisation over €25 billion up to €50 billion): The fees start from €110,000 in 2025, reaching €150,000 in 2027 and thereafter.
• Organised Trading Facility (Market Capitalisation over €50 billion): The fees start from €130,000 in 2025, reaching €170,000 in 2027 and thereafter.

Third Schedule (regulation 8) – Prospectus Fees

• Registration Document (Article 6 of the Prospectus Regulation): The fees are set at €3,500.

• Universal Registration Document (Article 9 of the Prospectus Regulation): Fees starting from €15,000.

• Registration Document for Secondary Issuances (Article 18 of the Prospectus Regulation): Fees starting from €3,250.

• Registration Document for EU Growth Prospectus (Article 15 of the Prospectus Regulation): Fees starting from €3,250.

• Securities Note (Article 6 of the Prospectus Regulation): Starting from €3,500.
  • Prospectus or Base Prospectus (Articles 6 and 8 of the Prospectus Regulation): Starting at €7,000.

• Securities Note for Secondary Issuances (Article 18 of the Prospectus Regulation): Starting from €3,250.

• Securities Note for EU Growth Prospectus (Article 15 of the Prospectus Regulation): Fees starting from €3,250.

• Supplement (Article 23 of the Prospectus Regulation): Fees starting from €1,500.

• Full Valuation Report for Immovables (Article 23 of the Prospectus Regulation): Fees starting from €1,000 per report.

• Full Valuation Report for Movables (Chapter 7 of the Capital Markets Rules): Fees starting from €2,000.

• Full Valuation Report for Other (Shares, Intangible Assets, etc.) (Chapter 7 of the Capital Markets Rules): Fees starting from €3,000.

• Condensed Valuation Report (Chapter 7 of the Capital Markets Rules): Fees starting from €500.

• Final Terms Filing Fee (Article 8 of the Prospectus Regulation): Fees starting from €50.

• Listing Fees:

• Equity Securities (Securities to be Listed): The listing fees for the latter are set at €15,000 for 2025.
• Collective Investment Schemes (Securities to be Listed): The listing fees for collective investment schemes are €2,000 for 2025.

5. Credit Institutions (Fees) (Amendment) Regulations, 2024

The amendments to Malta's Credit Institutions (Fees) Regulations, which are also effective starting from January 1, 2025, introduce several new and revised fees within the Banking Act in Malta. A €35,000 application fee now applies to companies seeking a banking license in Malta. For licensed institutions, modifications to their licenses incur a 75% reduced fee (€26,250) for adding activities or a flat fee of €1,000 for removing activities. Annual supervisory fees are calculated as a percentage of deposits, starting at 0.022% in 2025, with minimum thresholds increasing from €50,000 to €75,000 by 2029 and maximums capped at €1,700,000. European credit institutions establishing branches in Malta are required to pay a €3,600 notification fee and annual supervisory fees based on branch deposits (e.g., 0.022% in 2025, with minimums starting at €25,000 and maximums reaching €50,000 by 2029). Third-country credit institutions face a €35,000 license application fee and annual supervisory fees similar to European institutions but with higher minimum thresholds (up to €75,000) and maximums capped at €1,200,000. Additionally, non-Maltese companies establishing representative offices in Malta are subject to a €3,600 establishment fee, renewable annually. All fees are non-refundable, and except for prorated first-time supervisory fees, they are non-proratable.

Below is an outline of the updated fees:

• Credit Institutions (Application Fee): Fees start at €35,000 in 2025 and thereafter.
• Representative Office (Establishment Fee): Fees start at €3,600 in 2025 and thereafter.
• Branch by a European Credit Institution (Notification Fee): Fees start at €3,600 in 2025 and thereafter.
• Branch by a Third-Country Credit Institution (Application Fee): Fees start at €35,000 in 2025 and thereafter.
• Credit Institutions: Fees start at 0.022% of deposits (minimum €50,000, maximum €1,700,000) in 2025, rising to 0.030% of deposits (minimum €75,000, maximum €1,700,000) by 2029.
• Branches by European Credit Institutions: Fees begin at 0.022% of the branch's deposits (minimum €25,000, maximum €30,000) in 2025, rising to 0.030% of the branch's deposits (minimum €25,000, maximum €50,000) by 2029.
• Branches by Third-Country Credit Institutions: Fees begin at 0.022% of the branch's deposits (minimum €50,000, maximum €1,200,000) in 2025, rising to 0.030% of the branch's deposits (minimum €75,000, maximum €1,200,000) by 2029.

6. Financial Institutions (Fees) (Amendment) Regulations, 2024

The Financial Institutions (Fees) (Amendment) Regulations, 2024 implement significant changes to the fee structure under the Financial Institutions Act. Also applying from January 1, 2025, these updates redefine application and supervisory fees for institutions based on activities classified into Category 1 and Category 2, with fees increasing for institutions undertaking broader scopes of operations. A new calculation method incorporates total assets, transaction values, or average outstanding electronic money, capped at €250,000, to determine supervisory fees, with prorated fees applying only for the first year. For license modifications, institutions pay reduced application fees by 25% for adding new activities and a fixed €1,000 for discontinuing activities. The regulations also introduce separate registration and supervisory fees for account information service providers (€1,000 and €5,000, respectively), as well as new fees for European financial institutions establishing branches in Malta. Supervisory fees are now split into two installments, payable on January 1 and July 30 annually, offering enhanced flexibility. Additionally, all fees are declared non-refundable, and general prorating is excluded beyond specific cases. These amendments replace the previous regulations, safeguarding any fees accrued under the old framework, and aim to promote a clear, scalable, and equitable fee system for financial institutions operating in Malta.

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.