The Company Service Providers (‘CSPs’) Act was updated with the main aim of sharpening the focus of the regulatory framework applicable to CSPs through the introduction of two new categories of CSPs: Restricted (Notified) and Limited (Registered), which will be regulated under the same Act.
Restricted CSPs (notification)
Any natural person who, broadly:
- Acts as a director and/or a company secretary in a company and/or a partner in a partnership and/or holds a similar position in relation to other legal entities; and
- Does not do so by way of business; and
- Meets other prescribed requirements but mainly, does not hold an aggregate of more than five (5) involvements (including a maximum of two (2) groups of companies, where involvements of the same person within the same group of companies to be considered as one involvement).
The MFSA issued a guidance note outlining the process for completing and submitting the relevant notification form applicable to individuals acting as Restricted CSPs. Such notification should be made within fourteen (14) days from the date when the Restricted CSP first holds the position of a director or company secretary in a company, or a partner in a partnership, or a similar position in relation to other legal entities.
Limited CSPs (registration)
Any natural person who:
- By way of business, acts as a director and/or a company secretary in a company and/or a partner in a partnership and/or holds a similar position in relation to other legal entities; and
- Has or intends to have ten (10) or less involvements at any point in time.
Besides the amendments to the CSP Act, its subsidiary legislation and the MFSA Company Service Providers Rulebook, a new rulebook for Limited CSPs has also been introduced, which will solely be applicable to such Limited CSPs.
Under Threshold Class B CSP (authorisation)
The MFSA’s CSPs Rulebook was updated to reflect the change to the maximum number of involvements permissible by Under Threshold Class B CSPs from ten (10) to twenty (20). Individuals who prior to these changes were authorised as Under Threshold (‘UT’) Class B CSPs, now had the following options:
Exemptions
There are however, some instances where exemptions from authorisation/registration/notification (as set above) do apply. There are three specific instances in which exemptions apply, as outlined within the ‘Company Service Providers (Exemption) Regulations’. Furthermore, the following three instances are not considered as ‘involvements’ for the purposes of the CSP Act and the Rulebook: an individual who acts as director or company secretary of a company, a partner in a partnership or in a similar position in relation to other legal entities:
| i) in virtue of contract of employment | ii) due to a beneficial interest in such company, partnership or other legal entity, or | iii) due to a family relationship. |
FIAU guidance note
On 26 October 2025, Malta’s Financial Intelligence Analysis Unit (‘FIAU’) issued a guidance note addressed to CSPs subject to Registration (Limited CSPs). The following is an overview of some of its key points:
Stay up to date
with our latest Thought leadership
Contact us
