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.


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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.