Malta’s Citizenship Reform: Understanding Act XXI of 2025
In a decisive move that reshapes the landscape of Maltese nationality law, the Government of Malta has enacted Act XXI of 2025, amending the Maltese Citizenship Act (Chapter 188). This legislative reform, published in the Government Gazette on 24 July 2025, is not merely a procedural update, it represents a strategic recalibration of Malta’s citizenship policy in response to both domestic priorities and European Union (“EU”) legal standards. The impetus for these changes stems from the ruling of the Court of Justice of the European Union (“CJEU”) in Case C-181/23, which found aspects of Malta’s previous citizenship-by-investment scheme incompatible with EU law. In response, Malta has chosen to pivot toward a more principled and merit-based framework, reaffirming its sovereign right to define citizenship while embracing a more transparent and ethical model.
One of the most consequential outcomes of the reform is the complete abolition of the Malta Individual Investor Programme (“IIP”). Previously, the IIP allowed foreign nationals to acquire Maltese citizenship through substantial financial contributions, a model that drew criticism across the EU for commodifying citizenship. Act XXI of 2025 removes all legal references to the IIP, its agents, and related transactions, signalling Malta’s departure from transactional citizenship and its commitment to a system rooted in merit and national interest. This shift reflects a broader philosophical change, one that aligns with Malta’s long-term strategic vision, Vision 2050, which emphasizes innovation, ethical governance, and sustainable development.
The revised legislation also expands and clarifies the framework for citizenship by merit, a concept first introduced in 2017. Under the updated Article 10(9), individuals who have made exceptional contributions to Malta or to humanity may be considered for naturalization. The law now explicitly recognizes a diverse range of potential contributors, including scientists, researchers, cultural performers, athletes, entrepreneurs, philanthropists, and technologists. This inclusive approach reflects Malta’s desire to attract individuals whose talents and achievements can enrich the nation’s social, cultural, and economic fabric. Importantly, the merit-based pathway does not require a fixed financial contribution; instead, it evaluates applicants based on the substance and impact of their contributions, ensuring that citizenship is granted on the basis of genuine value rather than wealth.
In addition to merit-based reforms, Act XXI of 2025 introduces important clarifications regarding citizenship by descent and adoption. The deadline for individuals seeking to maintain a link to Maltese citizenship through descent has been extended to the 1st August 2028, offering greater flexibility to those with ancestral ties to Malta. Furthermore, amendments to Article 17 provide clearer guidelines for the eligibility of adopted children, ensuring that the process is consistent, fair, and aligned with contemporary standards of family law and child welfare.
To support the integrity of the new system, the legislation establishes enhanced oversight and due diligence mechanisms. Article 25A introduces a formal complaint procedure for individuals seeking redress in merit-based naturalization cases, while Article 25B creates a Monitoring Committee tasked with overseeing the evaluation process. Applicants must now undergo a thorough vetting procedure, which includes interviews and assessments by a dedicated board with the authority to consult sectoral experts. These measures are designed to ensure transparency, accountability, and public trust in the citizenship process.
The implications of Act XXI of 2025 are far-reaching. For Malta, the reform positions the country as a forward-looking EU member state that balances national sovereignty with legal compliance and ethical governance. By prioritizing merit over monetary investment, Malta aims to attract individuals who can make meaningful contributions to its development and global standing. For legal practitioners and prospective applicants, the new framework introduces a more nuanced and qualitative process, one that demands demonstrable impact and alignment with Malta’s values. And for the EU, Malta’s compliance with the CJEU ruling sets a precedent for responsible citizenship policy, reinforcing the principle that EU citizenship must be rooted in genuine connection and contribution.
Ultimately, Act XXI of 2025 is more than a legislative amendment, it is a visionary redefinition of Maltese citizenship. By embracing merit, transparency and national interest, Malta is crafting a citizenship model that is not only compliant with EU law but also reflective of its aspirations as a modern, ethical, and globally engaged nation.
