Important amendments to Malta's Beneficial Ownership Regulations were introduced by Legal Notice 184 of 2026 and came into force on 10 July 2026.

The amendments introduce additional reporting requirements, a simplified regime for certain ownership structures, and the new Form BO4. Companies should review their ownership and control arrangements during the six-month transitional period ending 10 January 2027.

Register of Members

Every company is required to maintain an adequate and up-to-date Register of Members at its registered office.

This obligation also applies where shareholders are natural persons. Under the new simplified regime, the Register of Members may, in certain circumstances, be deemed to constitute the company's Register of Beneficial Owners, provided that all the conditions outlined below are satisfied.

Simplified Regime for Straightforward Ownership Structures

A company's Register of Members will be deemed to constitute its Register of Beneficial Owners where:

• All registered shareholders are natural persons;
• None of the shareholders act as a trustee, nominee, or in any other fiduciary capacity;
• No natural person, other than a person disclosed in the Register of Members, ultimately owns or controls more than 25% of the voting rights or ownership interests in the company, or otherwise control over the company through any other means; and
• No natural person is identified as a beneficial owner solely by virtue of holding position of senior managing official

Where all of the above conditions are satisfied, the company will not be required to maintain a separate Register of Beneficial Owners or submit separate beneficial ownership declarations or notices to the Malta Business Registry ("MBR"), for so long as the conditions to be met.

Please note that companies satisfying all of the conditions of the simplified regime are not required to submit Form BO4, provided that these conditions continue to be met.

When is Form BO4 Required?

The new Form BO4 applies where all the company's registered shareholders are natural persons, but the company does not satisfy one or more of the conditions of the simplified regime outlined above.

For example, Form BO4 may be required where:

• A shareholder acts as a trustee, nominee, or in another fiduciary capacity;
• Another individual exercises ownership or control that is not reflected in the Register of Members; or
• An individual is identified as beneficial owner by virtue of being a senior managing official.

Companies must also take reasonable and appropriate steps to determine whether any natural person exercises control through means other than registered shareholding, including through voting arrangements, shareholder's agreements, or rights to appoint or remove directors. Any person identified as exercising such control must be treated and reported as a beneficial owner.

Companies registered before 10 July 2026 should assess whether the simplified regime applies to them. Where the BO4 is required, it must be submitted by 10 January 2027.

Failure to comply within the applicable period may result in an administrative penalty of €10,000 together with a daily penalty of €500 for as long as the default continues.

How DFK Malta Can Help

We can assist you in:

• Reviewing your company's ownership and control structure;
• Determining whether the simplified regime applies;
• Confirming whether Form BO4 or any other beneficial ownership filing is required;
• Reviewing and updating the company's Register of Beneficial Owners, where applicable, to ensure that all required information is properly recorded.

Should you require our assistance or further clarification on how these amendments may affect your company, please do not hesitate to contact us.

*The objective of this summary is to outline the principal elements of the rules being summarised herein. Accordingly, it is not intended to be provided by way of comprehensive and definitive advice. Readers should seek professional advice by contacting DFK Malta Tax & Consultancy Limited before acting upon any information included in this article. 

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