On 11 November 2025, the MFSA published its Feedback Statement in response to the 1 November 2024 consultation document on enhancing the regulatory framework for Company Service Providers (‘CSPs’). This Feedback Statement sets out stakeholder responses to the proposals and the MFSA’s position on each.
Key proposals and feedback
- Proposal to introduce two new concepts of Registration and Notification
- Notification regime (Notified Persons): This covers natural persons providing directorship and/or company secretary services not by way of business, up to 5 involvements and a maximum of 2 groups of companies. Many respondents welcomed the new category as more proportionate than full authorisation for independent directors, though concerns were raised about the threshold and the impact the new category might have on other CSP categories. The MFSA confirmed the 2-group cap remains and clarified that the notification is a one-off requirement, allowing the Authority to conduct a risk assessment on the basis of the information submitted in the notification forms, to be able to then take the necessary steps to ensure that risks are appropriately mitigated.
- Registration regime (Registered Persons): This category is aimed for individuals acting by way of business, with up to 10 involvements. Respondents generally supported the creation of this category, but some called for a higher threshold (20 involvements) and requested clarity around ongoing obligations, including AML obligations. The MFSA confirmed the 10-involvement cap and that Registered Persons will be “subject persons” under AML/CFT legislation.
- Proposal to create a specific rulebook for Registered Persons and streamlining of regulatory submissions
- The Authority had proposed issuing a dedicated Rulebook for Registered Persons. Stakeholders welcomed this, pointing out that it should clearly set out obligations applicable to that category and avoid duplication of regulatory burden.
- On streamlining submissions, a number of respondents suggested that such streamlining of regulatory submissions is applied to all licenses, and not just for Registered Persons. The MFSA noted that, together with the FIAU, is already working on a single regulatory return for Registered Persons, and will consider a similar approach for other types of CSPs in the future.
- Proposal to extend number of involvements of Class B under threshold CSPs to 20
- The consultation sought to raise the upper involvement limit for Class B Under-Threshold CSPs from 10 to 20. Stakeholders generally welcomed this increase in capacity, but some noted that this increase requires more robust systems in place to ensure adherence to obligations. The Authority noted that following an analysis of the compliance culture of the current Under Threshold Class B CSPs, these CSPs will continue to be exempt from having an independent Compliance Officer.
- General feedback and clarifications
- Amongst other matters, a number of respondents questioned on the required procedures if one decides to convert their authorisation to a registration, and if then opts to reconvert to an authorisation. Others provided opinions on foreign directors/company secretaries and streamlining the information between the Authority and the MBR. The MFSA acknowledged these comments and has indicated further work in future reviews of the CSP regulatory regime.
Overall, the Feedback Statement addresses a number of common concerns raised during the consultation process and offers important clarifications on the two new categories introduced. The MFSA explains the rationale behind its decisions on the respective obligations applicable to Notified Persons and Registered Persons, helping stakeholders better understand both the proportionality and supervisory intent of the revised framework. The Authority also suggested potential future enhancements, indicating that the CSP regime will continue to evolve in line with broader regulatory and AML/CFT objectives.
At Shoulder Compliance, we help CSPs navigate the above changes with tailored compliance and AML solutions. Reach out on info@shoulder.mt to learn more
