The Malta Financial Services Authority (MFSA), in collaboration with the Financial Intelligence Analysis Unit (FIAU), has announced the introduction of the Harmonised Regulatory Reporting Framework (HRRF), representing a significant step forward in the modernisation of Malta’s domestic regulatory reporting landscape. The initiative will transition domestic returns to a standardised, JSON-based reporting format, to be implemented on a phased, sector-by-sector basis.
Scope of Application
The HRRF applies specifically to domestic returns, namely, regulatory templates, returns, and reporting formats issued by the MFSA and/or the FIAU to address national supervisory requirements. These operate independently from reporting obligations stemming from the European Supervisory Authorities (ESAs) or other supranational regimes.
The framework will also include a revision of AML/CFT data points, aligning these with the forthcoming Regulatory Technical Standards under Article 40(2) of Directive (EU) 2024/1640 (AMLD6).
Key Benefits
According to the MFSA, the HRRF responds directly to industry feedback regarding the administrative burden of regulatory reporting. The framework aims to deliver:
- Reduced duplication by removing overlapping data requests across different domestic returns and authorities
- Streamlined data requirements through greater consistency and proportionality
- Enhanced efficiency by minimising operational burden and reducing data errors via a standardised reporting environment
Technical Support
To support implementation, the MFSA will provide a JSON conversion tool. This will enable Authorised Persons and their service providers to complete returns using familiar spreadsheet-based formats, which can then be converted into the required JSON format for submission. This solution is particularly relevant for entities that do not yet generate machine-readable JSON directly from internal systems or intend to adopt automated reporting at a later stage.
Implementation Timeline
The roll-out will take place in two phases:
Wave 1: CSPs, Registered Trustees of Family Trusts, Financial Institutions and CASPs
Mandatory JSON-based submissions will apply from January 2027. Key preparatory milestones include:
- Publication of technical taxonomies, reporting specifications, and JSON schema definitions: July–August 2026
- Industry testing phase (with access to testing environment): August–October 2026
- Industry seminar – Financial Institutions and CASPs: 11 September 2026
- Industry seminar – CSPs: 15 September 2026
- Industry seminar – Trustees of Family Trusts: 9 October 2026
Wave 2: Investment & Securities, Insurance & Pensions, and Remaining Trusts & Fiduciaries
Further details on timing and testing will be communicated following the completion of Wave 1.
Our Recommendation
Entities falling within Wave 1 are encouraged to begin assessing their readiness, including data mapping, system capabilities, and resource allocation, ahead of the testing phase scheduled for August to October 2026. Additional guidance, including technical documentation, testing access details, and seminar registration information, is expected to be issued by the MFSA in the coming weeks.
Shoulder Compliance will continue to monitor developments relating to the HRRF and will provide further updates as more detailed technical specifications become available. Clients seeking assistance with HRRF readiness, gap analysis, or reporting process enhancements are invited to contact our team.
