Malta’s 2025 Amendments to Trust Beneficial Ownership Rules: What Trustees Must Know

The Malta Financial Services Authority (MFSA) has issued important updates to the Trusts and Trustees Act (Register of Beneficial Owners) Regulations through Legal Notice 133 of 2025. These amendments, effective 11 July 2025, align Malta with the EU’s Sixth Anti-Money Laundering Directive (AMLD6) and significantly expand beneficial ownership reporting obligations for trusts.

Private Trustees Brought Into Scope

For the first time, private trustees under Article 43A of the Act are legally required to report beneficial ownership information to TUBOR. This ensures consistent transparency across all express trusts administered by trustees established or resident in Malta.

Private trustees must:

• submit beneficial ownership declarations for all existing trusts,
• comply with ongoing reporting and annual declaration requirements,
• update changes within 14 days.

A six-month transition applies: initial submissions are due by 11 January 2026.

Enhanced Access and AMLD6 Alignment

To meet EU standards, the regulations also:

• extend access to trust beneficial ownership data to any national competent authority defined under the PMLFTR,
• remove access rights previously granted to certain categories of persons,
• clarify what information must be supplied by those demonstrating “legitimate interest”.

These updates strengthen transparency and ensure proper use of beneficial ownership information.

Wider Compliance and Enforcement Powers

With expanded reporting obligations, the MFSA can now impose administrative penalties on private trustees and, where applicable, foreign trustees who fail to comply. Annual reporting requirements have also been extended to these groups.

This harmonises oversight across all trustee categories and reinforces the need for timely, accurate reporting.

Use of TUBOR and Practical Guidance

All submissions must be made via the TUBOR online portal (tubor.mfsa.mt).
The MFSA has issued explanatory videos to assist both corporate and individual trustees with account setup and filing procedures.

Authorised trustees providing services as “qualified persons” are expected to support private trustees in meeting these new obligations.

Looking Ahead

Further amendments to transpose additional AMLD6 requirements and EU Regulation 2024/1624 are expected in the coming months. Trustees should monitor MFSA communications to stay current with ongoing changes.