Key changes include a revised fee structure, the introduction of a temporary residence permit for applicants pending final approval and guidelines on the use of the qualifying immovable property, whether rented or purchased.
Additionally, the responsibility for agent licence administration has been transferred from the Community Malta Agency to the Residence Malta Agency ("RMA"), further consolidating the RMA's role in overseeing the MPRP.
Agent licence
An agent was previously required to assist with the submission of both MPRP applications and citizenship by investment applications. The registration, renewal and administration of agent licences were managed by the Community Malta Agency. Following the ECJ judgment, the Maltese citizenship by investment programme has been suspended. In its place, a new bill focused on citizenship by merit has been tabled in the Maltese Parliament and is expected to become law in the coming weeks. This upcoming framework will not require the involvement of licensed agents for the submission of citizenship applications.
Nevertheless, for those applying under the MPRP, the role of licensed agents remains essential. As a result, the responsibility for agent registration, administration and annual licence renewals will now be handled by the RMA ensuring compliance with the MPRP framework.
Temporary residence permit
Previously, applicants submitted their MPRP application and were issued a residence card upon approval. Following these amendments, the RMA has introduced a temporary residence permit which must now be applied for at the start of the MPRP process.
This temporary residence permit is valid for 1 year and allows applicants to reside in Malta while their MPRP application is being processed. Applicants are required to submit the full MPRP application within 6 months of the residence permit's issuance.
If the MPRP application is approved, the temporary residence permit will be converted into a permanent residence card in line with the MPRP. If the MPRP application is refused, the temporary residence permit will be revoked within 15 days of the issuance of the refusal letter.
Changes to the application fees
| Type of fee | Applications submitted by 31 December 2024 | Applications submitted on or after 1 January 2025* |
|---|---|---|
| Administrative fee (main applicant) | €50,000 | €60,000 |
| Contribution (main applicant) | €60,000 (if property is rented) €30,000 (if property is purchased) |
€37,000 (no difference if property is bought or rented) |
| Contribution (each dependent) | €5,000 | X |
| Administrative fee (each dependent) | €5,000 | €7,500 Applies only for:
|
*The above change in fees shall apply to applications submitted after 1 January 2025 which are not yet concluded.
Property use
To qualify for the MPRP, applicants must either purchase or rent immovable property in Malta. The minimum annual rent must be €14,000 while the minimum purchase price must be €375,000.
Regulation 12 of the Legal Notice introduces the possibility for the RMA to issue guidelines governing the use of such immovable property. According to current guidance provided by the RMA, applicants who purchase property may lease it to third parties for temporary periods during which they are not residing in Malta. In the case of rented property, applicants may sublet the property, but only after the initial 5-year lease period has elapsed and subject to the landlord's prior consent.
These amendments remove the difference in contribution amounts based on whether the property is rented or bought and eliminate the contribution fee for additional dependents. Additionally, RMA's guidance on the use of immovable property offers a more flexible and practical approach allowing applicants to generate a return on investment during periods when they are not residing in Malta. These changes reflect Malta's commitment to maintaining a competitive and attractive residence programme for non-EU nationals.
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.
