Malta citizenship for exceptional services: what the 36-month track was, and what the law says now
The "36-month track" was a feature of Malta's 2020 regulations on citizenship for exceptional services by direct investment. The law underneath it has since changed. The Maltese Citizenship (Amendment) Act, 2025 (Act XXI of 2025), assented to on 24 July 2025, rewrote the provision those regulations relied on, and Community Malta Agency now describes the route as citizenship by naturalisation on the basis of merit. This page sets out what the 2020 text said and what the current official sources say.
What the 2020 regulations provided
The Granting of Citizenship for Exceptional Services Regulations, 2020 were published as Legal Notice 437 of 2020. The figures below come from that original text and are given as history, not as a description of what is open today.
| Item | Legal Notice 437 of 2020, as published |
|---|---|
| Residence before applying | Proof of residence in Malta for 36 months, reducible by exception to a minimum of 12 months subject to an exceptional direct investment (regulation 16(1)(a)) |
| Direct investment | €600,000 for the applicant, or €750,000 where the application was submitted before completing 36 months of residence (First Schedule) |
| Property | Purchase of residential property worth at least €700,000, or a lease at a minimum annual rent of €16,000, kept for five years from the date of the certificate (regulation 16(1)(b)) |
| Donation | At least €10,000 to a registered non-governmental organisation or society, or as otherwise approved by the Agency (regulation 16(1)(d)) |
| Numerical limit | No more than 400 certificates a year and 1,500 in total, excluding dependants (regulation 19) |
The 2020 text contains a 36-month period and an exceptional 12-month period. It does not contain a 60-month track.
What Act XXI of 2025 changed
Act XXI of 2025 amended the Maltese Citizenship Act (Cap. 188) in three ways that matter here.
- It deleted the definition of "individual investor programme" from article 2 of the Act.
- It replaced article 10(9). The Minister may now grant a certificate of naturalisation "by merit" to a person who renders exceptional services or makes an exceptional contribution, including through job creation, to Malta or to humanity, or whose naturalisation is of exceptional interest to Malta. The Act says "exceptional" means manifestly superior or adding value, and it names scientists, researchers, athletes, sports persons, artists, cultural performers, entrepreneurs, philanthropists and technologists among the people it has in mind.
- It replaced article 25A, so that the Regulator may investigate complaints about the application process for naturalisation on the basis of merit where an application was refused, and presents conclusions to the Minister.
The Act also includes a saving provision: it does not apply to applications for naturalisation filed under article 10(9) before it came into force, subject to any regulations made under the Act.
The route as the Agency describes it now
Community Malta Agency's note on citizenship by naturalisation on the basis of merit states that Subsidiary Legislation 188.06 is now titled the Granting of Citizenship by Naturalisation on the Basis of Merit Regulations, and that a grant is discretionary and treated case by case. The process it describes runs as follows.
- The applicant first submits a detailed proposal letter to the Agency, setting out background and achievements, the exceptional service or contribution made or intended, and a forward-looking plan, with supporting documents.
- An autonomous specialised board evaluates the proposal, with due diligence carried out by the Agency, and makes a recommendation. The Minister gives approval in principle or rejects. The note states that the Minister is not obliged by law to give reasons and that the decision is final.
- After approval in principle, the applicant may submit the formal application by proving at least eight months of residence in Malta and title to adequate residential property there, demonstrating the exceptional service, contribution or interest with the endorsement of the designated competent body, confirming knowledge of Maltese or English, and showing the other ties created with Malta.
- The board reviews the application again and the Minister decides. If approved, the applicant and any included dependants take the oath of allegiance and receive the certificate.
The note adds that the Minister may deprive a person of citizenship granted on merit if that person fails to comply with a material obligation or commitment, and that the Agency prohibits marketing of these processes.
What the official sources do not state
The Agency's note does not set a contribution amount, a fee schedule, a quota or a processing time for merit applications; it says only that fees established by the Agency apply. We have not located an official publication giving approval or refusal figures, and we do not publish estimates. Material that still presents a fixed-price 36-month route as currently open does not match the Act as amended.
Anyone with an application filed before 24 July 2025 should read the saving provision in Act XXI together with any regulations made under it, and take advice from a Maltese lawyer or a professional authorised by the Agency.
Always confirm against the official page: Acquisition of Citizenship (Aġenzija Komunità Malta).