Residency Malta Agency FAQs updated for 2025 Malta Permanent Residence Programme Applications

Upon publication of Legal Notice 310 of 2024, as published on the 19th of November 2024, the Residency Malta Agency (RMA) updated the Frequently Asked Questions (FAQs) on their official website to cater for Malta Permanent Residence Permit (MPRP) applications that will be submitted from 1st January 2025. Such updates were necessary following the regulatory amendments that will bring about changes to Malta’s Permanent Residence Programme as of 2025.

As stated on the official RMA MPRP FAQs page, such FAQs are meant as general guidelines for use by licensed agents, and in case of conflicting views between the Frequently Asked Questions and the pertinent legislation, it is S.L. 217.26 (as amended by Legal Notice 310 of 2024) that prevails.

A collection of 15 updated FAQs published by the Residency Malta Agency are being reproduced below to help provide clarity for prospective applicants that may submit their Malta Permanent Residence Permit application from 1st January 2025:

• Eligibility, Administration Fee, Contributions and Donation

Can parents or grandparents of the main applicant apply as dependants?

Yes. A parent or grandparent of the main applicant or of his/her spouse who proves to the satisfaction of the Agency that at the time of application he/she is principally dependant on the main applicant, is eligible as a dependant. The main applicant shall provide an affidavit confirming that he supports each parent or grandparent. If a parent or grandparent is applying as a dependant, proof that shows the link between the grandparent and the main applicant/spouse has to be provided (such as a family tree through birth certificates of the applicant/spouse, the birth certificate of the respective parent, and grandparent). An additional fee of €10,000 per parent and grandparent applies.

What administration fee applies for each application?

An administration fee of €50,000 for each application applies. A non-refundable initial fee of €15,000 should be paid to the Agency within one month of submission of the application. The remaining €35,000 is required to be settled within two months of the issuance of the Letter of Approval in Principle.

In case of an application for the entire family, what contributions need to paid?

The contribution fee of €30,000 (if purchasing property) or €60,000 (if leasing property) covers the main applicant. An additional fee of €10,000 applies to each dependant.

• Qualifying Property

A client explained that he has just bought a property in the South of Malta for circa EUR 220,000 and will be spending a minimum of EUR 100,000 on it - therefore the total cost to him will be in excess of the EUR 300,000 required for a property in the South. Will this be considered as a satisfactory property investment?

Yes. Provided that the property, situated in Malta or Gozo, is purchased before the date of application and on which works have been carried out at the expense of the client after the purchase, shall be considered to be a qualifying owned property insofar as the value of such property is not less than €375,000 as supported by an independent architect’s detailed valuation report including a plan of the property and a description of works undertaken. The Agency may, in its discretion, appoint an architect to determine the value of the qualifying owned property. In such case, officers of the Agency and/or any architect appointed by the Agency for this purpose shall be granted full and free access to the qualifying owned property to the extent that such access is likely to assist in determining the value of the said property. In all cases, it is within the power of the Agency to decide whether the requirements are satisfied.

Note: For applications submitted from 1st January 2025 the distinction between the South of Malta, Gozo and the rest of Malta will cease.

• Proof of Assets

It is quite normal for a property to be co-owned by the main applicant and his/her spouse, children and sometimes grandparents. Would this be accepted as evidenced of the EUR 500,000 capital?

Capital can either be €500,000 or €675,000. Only the spouse’s part of the property is taken into consideration and only if the spouse is part of the application.

If applicant is in possession of assets amounting to EUR 500,000 (out of which EUR 150,000 should be in the form of financial assets), it the amount applicable only to main applicant or is it applicable also to the other listed dependants?

The possession of assets can either be of €500,000 (out of which €150,000 should be in the form of financial assets or else €675,000 (out of which €75,000 should be in the form of financial assets). The amount is applicable only to main applicant. The amount does not change according to the number of persons included in the application.

Can an applicant be eligible with a EUR 100,000 yearly employment income, as was required in the MRVP?

No, applicants can no longer be eligible by showing a yearly employment income of €100,000. Applicants need to show assets of €500,000 or €675,000.

With respect to the monitoring of assets, for how long will the beneficiary need to be compliant and in what form should these declarations be presented to the Agency?

Monitoring of beneficiary’s €500,000 in assets, out of which a minimum of €150,000 need to be in financial assets or €675,000 in assets, out of which a minimum of €75,000 need to be in financial assets will be made yearly for the first 5 years. The declaration is to be made through the submission of Form MPRP5 (Official Compliance Form), which is to be signed by the beneficiary and by the licensed agent.

Is the EUR 500,000 capital requirement distinctive from the value of property acquired/leased in Malta?

Yes, they are different, distinctive requirements. Clients should provide:

1. proof of €500,000 capital, out of which a minimum of €150,000 should be financial assets or else proof of €675,000 capital, out of which a minimum of €75,000 should be financial assets and

2. property valued at €375,000 or rent of €14,000 per annum.

Not many people keep cash in a bank account for a long time. They may have investment in property, security, or business. Can an applicant present a security/investment portfolio and/or property appraisal and/or company financial statements?

Yes, these documents are acceptable as long as they are issued from a reputable company or an official entity. These documents will accompany the necessary MPRP forms, including Form MPRP2 in which the statement of source of funds and wealth has been incorporated. The Agency is interested in the ‘individual’ financial capabilities, and the applicant must convince the Board that they have sufficient funds to satisfy the MPRP requirements with regards to qualifying property, and sustain themselves and their dependants while at the same time satisfy the programme qualification criteria of €500,000 in capital out of which a minimum of €150,000 shall be in the form of financial assets or else €675,000 in capital, out of which a minimum of €75,000 should be in the form of financial assets. What is important is that reliable evidence is presented to sustain applicant’s declaration.

With regards to the €500,000 capital requirement, would an architect’s valuation be acceptable as evidence in order to establish the total net assets of a client if his/her assets were primarily real estate (and not necessarily cash or other liquid assets)?

Yes, an architect’s valuation is acceptable and real estate can form part of main applicant’s capital requirement.

Note: For applications submitted from 1st January 2025, the capital requirement can either be €500,000 or else €675,000

• Submission of Application

How would the initial non-refundable fee be settled?

A non-refundable fee of €15,000 must be paid. The fee must be transferred via an electronic bank transfer to the Agency. At the time the application pack is accepted by the Agency, a request for payment is handed over to the licensed agent, who will instruct the main applicant to effect payment within one month directly from the bank account specified in Form MPRP2 to the Agency’s bank account, quoting the application reference number.

• Issuance of Letter of Approval in Principle, Residence Certificate, Residence Cards and Biometrics

What is the process to be followed, right after the application is duly submitted?

An application pack is to be submitted complete and correct including full supporting documents. Incomplete application packs will not be accepted by the Agency. For a list of documents and forms to be submitted, kindly refer to the Agent Handbook, available on our website.

In order to submit a new application, the agent should set an appointment with Client Relations and Compliance. During the appointment, the agent shall submit the application pack with the receptionist or a Client Relations and Compliance employee, as applicable. The agent shall be given a receipt of submission, which does not mean that the file is formally accepted by the Agency.

Once the application pack is vetted and accepted by the Agency, a formal receipt is issued, and the applicant is requested to settle the initial non-refundable fee of €15,000 within one month. On receipt of funds, due diligence checks on main applicant and dependants are conducted. If successful, the application is presented to the Board of Approvals and, if approved, a Letter of Approval in Principle is issued.

Following this, the main applicant is required to settle the contribution, buy/lease the qualifying property, make the donation and purchase the necessary health insurance cover. Once main applicant provides all the documentation, the Agency will issue the residence certificate within 7 days, provided that all documentation is finalised and deemed acceptable.

The Agency will also issue a Letter of Final Approval to main applicant (the beneficiary), inviting them and their dependants to call at our offices for the capturing of biometric data. Once the biometrics are captured, and all residence forms collected, the application is sent to the department of residence for printing. The printing of residence cards currently takes circa 2 weeks per application.

• Compliance

Is the requirement to show €500,000 capital valid just for the first 5 years?

The beneficiary is required to hold the €500,000 capital with €150,00 in financial assets or else hold the €675,000 capital with €75,000 in financial assets for the first five years only

Note: For applications submitted from 1st January 2025, the capital requirement should either be €500,000 or else €675,000.

• Applicants Wishing to Change to Another Programme

If an applicant who has already submitted an application under the MPRP decides to apply for a Citizenship for Exceptional Services, will the administrative fee be deducted from the Citizenship for Exceptional Services application fees?

No. The €50,000 fee paid for MPRP is non-refundable and non-transferable.

Source: https://residencymalta.gov.mt/faqs-application-new/ as accessed on 20/11/2024.

Attard Baldacchino - Trusted Expertise and Qualifications

Our founder, Dr. Russell Attard Baldacchino, is a Maltese Advocate, warranted to practice law in the Republic of Malta and licensed agent AKM-BALD by the Community Malta Agency and the Residency Malta Agency. Dr. Attard Baldacchino is also a Malta-licensed Real Estate Agent EA-00174-24, an Authorized Registered Mandatory by the Malta Commissioner for Revenue, a member of the Malta Chamber of Advocates and the Malta Institute of Taxation.

If you have any questions or need further assistance with the Malta Permanent Residence Programme (MPRP), don't hesitate to reach out to Attard Baldacchino. You can contact us via email at admin@ab.eu or on WhatsApp at +356 7928 4155. Attard Baldacchino and his team are ready to help you navigate the application process and answer any queries you may have.