Malta's New Migration Policy: What Third Country Nationals Need To Know In 2025

Malta is implementing sweeping changes to its labour migration system in 2025, fundamentally transforming how Third Country Nationals (TCNs) work and live in the country. These reforms, spearheaded by Home Affairs Minister Byron Camilleri, represent the most significant overhaul of Malta's migration framework in recent years, with implications for both employers and foreign workers.

Overview of the Malta Labour Migration Policy

The new Malta Labour Migration Policy is built on four core principles: retention and stability, protection of employee rights, aligning labour migration with labour market needs, and a skills-based approach to migration. With Malta's population now comprising 22.2% foreign nationals, predominantly economic migrants vital to the nation's growth, these changes address growing concerns about worker exploitation while ensuring sustainable economic development.

Timeline of Implementation

The policy rollout follows a phased approach designed to avoid shocking the system while giving employers and employees time to adjust:

Phase 1 (August 1, 2025): 12 measures implemented
Phase 2 (October 1, 2025): 3 additional measures

Ongoing Implementation: 5 measures introduced on a rolling basis through July 2026

Key Changes Taking Effect August 1, 2025

1. Termination Rate Monitoring

One of the most significant changes targets employers with excessive termination patterns. Companies with high termination rates relative to their workforce size will fail the Labour Market Test, effectively barring them from recruiting new TCNs. For small firms, termination rates exceeding 50% will disqualify them from hiring non-EU workers. This measure will be gradually implemented with phased introduction through July 1, 2026.

2. Mandatory Job Vacancy Requirements

Before applying to hire TCNs, employers must now advertise positions for 2-3 weeks to allow sufficient time for Maltese, EEA, Swiss nationals, or TCNs already in Malta to apply. From October, this must be done via Jobsplus and EURES portals. If employers receive applications from eligible candidates and reject them, they must provide justification to Jobsplus for evaluation.

3. Revised Fee Structure

The fee system has been restructured to encourage worker retention:

First-time applications: €600 (doubled from €300)
Annual renewals: €150 (halved from €300)
Change of employer: €600
Change of role: €300
Healthcare/elderly/disability care sectors: Capped at €150 for all applications

4. Extended Grace Period for Terminated Workers

TCNs whose employment is terminated now have an extended 60-day grace period (30 days plus an additional 30 upon proof of financial stability) to find new employment before being required to leave Malta. This prioritises retention of skilled individuals already familiar with Malta over newcomers.

5. Increased Salary Thresholds for High-Skilled Programs

The minimum salary requirements for Malta's fast-track employment programs have been revised upward:

Key Employment Initiative (KEI): €45,000 annually (increased from €35,000)
Specialist Employee Initiative (SEI): €30,000 annually (increased from €25,000)

Changes Taking Effect October 1, 2025

1. Electronic Salary Payments Mandatory

All salary payments to TCNs registered from August 1, 2025 onwards must be conducted exclusively via licensed financial institutions through electronic payments. Cash payments will no longer be recognised as fulfilling employment contract requirements, ensuring transparency and compliance.

2. Interim Permits for Visa Waiver Nationals

TCNs from visa-exempt countries who apply for a single permit within 60 days of entering the Schengen Area will be granted interim permits allowing them to remain in Malta while their application is processed. However, those applying between 61-90 days must await the outcome from outside the Schengen Area.

3. Enhanced Support for Human Trafficking Victims

Individuals recognised as victims of human trafficking will be exempt from application fees, and their residence permits will be valid for one year rather than the current six months.

Additional Ongoing Measures

Integration Requirements

A restructured "I Belong" programme will introduce mandatory pre-departure integration courses. Identity Malta will only issue approval in principle after TCNs provide documented evidence of completing these courses. Participants must demonstrate fluency in either Maltese or English and receive essential information about legal rights, cultural norms, and opportunities in Malta.

Enhanced Compliance Monitoring

New verification checks will ensure conditions from original contracts, including wage requirements, are maintained during renewals.

Register of Exemplary Employers

A new register will be created for employers meeting certain criteria, offering streamlined labour market testing processes and improved efficiency. Employees working for registered employers will be eligible for renewal periods of more than two years and up to four years.

Legal Framework and Government References

These changes are implemented under Malta's comprehensive legal framework governing TCN employment:

Primary Legislation:

Immigration Act (Cap. 217)
Employment and Training Services Act (Cap. 594)

Key Subsidiary Legislation:

S.L. 217.17: Single Application Procedure for Single Permits
S.L. 217.06: Family Reunification Regulations
Legal Notice 310 of 2024: Malta Permanent Residence Programme amendments

Government Agencies Involved:

Identità (formerly Identity Malta Agency): Processes residence permits and single permits
Jobsplus: Conducts labour market tests and issues employment licenses
Residency Malta Agency: Manages permanent residence programmes
Ministry for Home Affairs, Security and Employment: Policy oversight under Minister Byron Camilleri

Impact on Current TCN Workers

The policy includes important protections for existing workers:

Measures are not retroactive - current TCNs are not negatively affected by new restrictions
Electronic payment requirements only apply to new registrations from August 2025
Extended grace periods provide better job security for terminated workers
Lower renewal fees benefit existing workers staying with current employers

Exemptions and Special Provisions

Several categories enjoy exemptions from standard requirements:

Partners or parents of Maltese nationals under 23 are exempt from single permit processes (though work licenses are still required)
Essential occupations maintaining Malta's critical services
Students and sportspeople under specific regulations
Healthcare, elderly care, and disability care sectors have reduced fees

Compliance and Enforcement

The government has emphasised a gradual implementation approach to avoid system shock. Employers are encouraged to review upcoming applications and renewals to ensure alignment with new requirements. Non-compliance may result in:

Application rejections and processing delays
Disqualification from hiring TCNs
Enhanced scrutiny and monitoring
Potential legal consequences under Immigration Act provisions

Looking Ahead

These reforms represent Malta's commitment to creating a transparent, skills-based, and fair employment framework that balances economic needs with social priorities. As Minister Camilleri noted, the policy addresses the reality that "the economy we have today is not the same as when unemployment was the biggest concern".

The changes aim to combat exploitation, protect worker rights, and ensure TCNs are employed where genuinely needed while maintaining Malta's economic competitiveness. For legal practitioners and their clients, staying informed about these evolving requirements will be crucial for successful navigation of Malta's new migration landscape.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.