Malta overhauls beneficial owner filings, with a January 2027 deadline for existing companies
Malta's Companies Act (Register of Beneficial Owners) (Amendment) Regulations 2026 (Legal Notice 184 of 2026) came into force on 10 July 2026. A company may treat its register of members as its beneficial owner record only if strict conditions are met; otherwise it must file a new declaration, including on the new Form BO4. Place of birth and residential address are now required, access is split into three tiers with a legitimate-interest route, and existing companies have until 10 January 2027.
The regulations are the second stage of Malta's transposition of the EU's sixth anti-money laundering directive (2024/1640). The first, Legal Notice 127 of 2025, widened the entities covered and reopened access to people with a legitimate interest.
What changed
- Register of members as the BO record: allowed only if all shareholders are individuals, none acts as trustee or nominee, no one else owns or controls more than 25%, no one controls by other means, and no senior managing official is named as beneficial owner.
- Form BO4: a new declaration for companies whose shareholders are all individuals but whose arrangements still need assessment.
- More data: each beneficial owner's place of birth and residential address.
- Access: three tiers. Legitimate-interest applicants apply in writing with ID and supporting documents, and refusals can be appealed.
- Deadline: companies registered before 10 July 2026 have six months, to 10 January 2027, to assess their position and file any new declaration.
What to do
Check every Maltese company against the conditions and file Form BO4 or a fresh declaration before 10 January 2027.