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MRVP FAQ V5.0 of 24 Copyright © 2017 Identity Malta Agency. All rights reserved

Frequently Asked Questions

These Frequently Asked Questions are meant as general guidelines to particular situations which have been

referred to Identity Malta Agency. In case of conflicting views between these Frequently Asked Questions

and the pertinent legislation, it is the LN288 of 2015 that prevails.

The replies given in latest version of this document prevail over those given in previous versions. The latest

version is the one found on the MRVP website.

1. Eligibility & Fees

Q1.1 Who is eligible to apply?

R1.1 European Union nationals are not eligible to apply, since the provisions of our regulations themselves

exclude them from applying. All other nationals are eligible, excluding nationals from Afghanistan and

North Korea. In the future, applications from other countries may also be excluded in accordance with

Government policies.

Q1.2 Can parents or grand-parents of the Main Applicant be applied for as dependants?

R1.2 Yes. A parent or grandparent of the Main Applicant or of his/her spouse, who proves to the satisfaction

of the Minister that he/she is not economically active and is principally dependant on the Main

Applicant, is eligible as a dependant. If a grandparent is being applied for as a dependant, proof that

shows the link between the grandparent and the Main Applicant/spouse has to be provided (such as

for example a ‘family-tree’ through birth certificates of the Applicant/spouse, the birth certificate of

the respective parent, and then the grandparent).

Q1.3 Can household staff be eligible as dependants?

R1.3 No. For the time being, the Malta Residence and VISA Programme is only open to Main Applicant and

his/her family dependants.

Q1.4 In the case of an application for the entire family, are there additional fees?

R1.4 No. The €30,000 covers the entire family. However a residence card processing fee applies when a

residence card is issued or renewed. The fee is of €27.50 for a one-year time period per person. Hence

a card valid for 5 years carries a fee of €137.50.

Q1.5 What is the validity period of the Residence Certificate and the Residence Card?

R1.5 The Residence Certificate does not expire. The Residence Card is valid for 5 years.


2. Qualifying Investment

Q2.1 What form of investment is acceptable? LN288 mentions an investment of €250,000 in Government

bonds and stocks.

R2.1 For the time being the Qualifying Investment will consist of Government Stocks, equivalent to

€250,000 (Market Value). These stocks/bonds can be purchased from a suitable stockbroker. Identity

Malta Agency will need a receipt or a certified true copy of the purchase agreement.

Q2.2 Can an Applicant open an account in Malta?

R2.2 An Applicant may open an account in Malta at his/her discretion.

Q2.3 What is the return the Beneficiary gets on the Qualifying Investment? At what interval is interest paid?

R2.3 This does not fall within the remit of Identity Malta Agency. Matter is to be discussed with a qualified

stock broker and/or banking institution.

Q2.4 What is the procedure for buying the Qualifying Investment?

R2.4 This has to be tackled with a qualified stock broker and/or banking institution. Identity Malta Agency

would need a certificate confirming this investment.

Q2.5 After the initial 5 years, with regard to the qualifying investment, can the Applicant sell the bonds and

still hold a Maltese residency?

R2.5 Yes he may sell the qualifying investment after 5 years and still retain Maltese residency on condition

that other requirements stipulated in LN 288 of 2015 are still met.

Q2.6 Will the Beneficiary be required to retain an investment portfolio, after having satisfied the obligation

holding this for five years, for the residence card to be re-issued?

R2.6 No. He/she may sell the qualifying investment portfolio.

Q2.7 Can the Applicant take a loan to buy the Qualifying Investment?

R2.7 This is at the discretion of the Bank.

Q2.8 Are the Funds which invest exclusively in Malta Government Bonds accepted as a form of qualifying

investment?

R2.8 Yes, they are.


3. Qualifying Property

Q3.1 Do Applicants need to own/lease property at application stage?

R3.1 No, not necessarily. The Applicant has to own/lease property after receiving the Letter of Approval in

Principle. However, a property that would have been leased/purchased before the application

submission and which satisfies the rules found in LN288 of 2015 regarding the Qualifying Property, is

still acceptable.

Q3.2 Can the Beneficiary sell or stop leasing the declared qualifying property during the first five years and

replace it with another qualifying property?

R3.2 Yes, during the first five years the Beneficiary can sell the qualifying property and buy/lease a new

property as long as he continuously satisfies the qualifying property conditions. He would have to

inform the RAP/RAA who in turn should inform Identity Malta Agency. A certified true copy of the

purchase/lease agreement of the new qualifying property has to be submitted to IMA as evidence.

Q3.3 Would the Beneficiary have to commit himself not to sell the property for the first five years if he

decides to purchase a property? How would this be monitored in practice?

R3.3 No the Beneficiary does not have to commit himself not to sell the qualifying property. This can be

sold as long as it is replaced by another qualifying property. The monitoring happens on an annual

basis for the first 5 years through the submission of a Form MRVP5 - Official Compliance Form, which

is to be signed by the Beneficiary and the RAP/RAA and submitted by the RAP/RAA to Identity Malta

Agency. After the first five years, monitoring will happen once every five years.

Q3.4 Would purchasing a number of rooms in a hotel and owning these for a period of 5 years, naturally

without anyone else having access to the rooms in the meantime, qualify?

R3.4 No, these are not accepted as a Qualifying Property. The Main Applicant must lease or purchase a

residential property.

Q3.5 A client explained that he has just bought a property in the South of Malta for circa €190,000 and will

be spending a minimum of €100,000 (arising outside Malta) on it - therefore the total cost to him will

be in excess of the €270,000 required for a property in the South. Will this be considered to satisfy

property investment of the Malta Residence and VISA Programme?

R3.5 If the purchase of the property has happened after LN288 of 2015 came in to force, the determining

factor is the value of the property as declared on the contract of sale. Therefore the said scenario does

not satisfy the Qualifying Investment criteria.

If, on the other hand, the property were bought PRIOR to the date of coming in force of LN288 of 2015,

the following prevails:


“Provided that an immovable property purchased before the date of coming into force of these

regulations for a consideration which is less than the amounts indicated in paragraphs (a) or (b) above

shall be considered to be "qualifying owned property" insofar as the value of such immovable property,

as declared on the date of application by the Applicant, is not less than the amounts indicated in

paragraphs (a) or (b) above as supported by a separate and independent architect valuation including

architect’s plan which are delivered to Identity Malta Agency upon application: Provided further that

Identity Malta Agency, or any officer authorised by it in writing, architect or surveyor shall have full

and free access to the qualifying owned property to the extent that such access is likely to assist him in

determining the value of the said property;”

Therefore, the value must be met at the date when the application is submitted and not after the

Letter of Approval in Principle is issued.

Q3.6 Would an AIP permit (to buy or rent) the qualifying property be required for a non-EU citizen who is

applying under this Programme if the property is not in a ‘special designated area’?

R3.6 Yes, the acquisition of immovable property (AIP) permit is still required.

Q3.7 Would the minimum property requirements no longer apply, after a qualifying property has been held

for the first 5 years?

R3.7 The Beneficiary is not obliged to retain possession of the Qualifying Property stipulated in the

respective legal notice. However, to retain residence he must provide a suitable residential address.

Q3.8 Is it possible for the Main Applicant to first rent and then buy a property?

R3.8 Yes, it is possible, as long as the qualifying criteria are satisfied in both stages.

Q3.9 Can the Applicant take a loan to buy the Qualifying Property?

R3.9 This is at the discretion of the Bank.

Q3.10 During application stage Applicant undertakes to fulfil the obligation to buy or rent the property in

Malta together with the investment obligation. Is an affidavit enough or do you need a promise of

sale/rent agreement?

R3.10 The declaration is part of form MRVP1, which needs to be signed before a Commissioner of Oaths.


Q3.11 It is quite normal for property to be co-owned by the Main Applicant and his/her spouse, children and

sometimes grandparents. Would this be accepted as evidence of the €500,000 capital?

R3.11 Co-ownership is acceptable up to and including spouse and children, as long as the spouse and the

children are included in the application If, the Main Applicant is applying on his/her own, only the

value of his/her individual share will be accepted as forming part of his/her declared capital.

4. Proof of Assets

Q4.1 If the Applicant is in possession of assets amounting to €500,000, or an annual income of €100,000

(arising outside Malta) – is the amount applicable only to the Main Applicant or is it applicable also to

the other listed dependants?

R4.1 The amount is applicable to the Main Applicant only.

Q4.2 If the Applicant is in possession of assets amounting to €500,000, or an annual income of €100,000

(arising outside Malta) – does this amount change if the application is for the Main Applicant and other

dependants?

R4.2 No the amounts do not change with the number of persons covered under one application.

Q4.3 With respect to monitoring requirements, if the certificate is provided on the basis that he/she has in

his/her possession assets amounting to €500,000, or if the Applicant is in possession of an annual

income of €100,000 (arising outside Malta), does this monitoring requirement also apply for

dependants listed on the certificate? And in what form should these declarations be presented to

Identity Malta Agency?

R4.3 No, monitoring of assets will only be conducted on the Main Applicant and is not applicable to

dependants. The declarations will be made through the submission of form MRVP5 Official

Compliance Form, which is to be signed by the Beneficiary and the RAP/RAA and submitted by the

RAP/RAA to Identity Malta Agency. The Beneficiary signs to endorse that the information submitted is

true, factual and correct. The RAP/RAA signs for administrative purposes only. After the first five years,

monitoring will happen once every five years.

Q4.4 Is the €500,000 capital requirement distinctive from the value of property acquired in Malta together

with the €250,000 invested in government stocks?

R4.4 Yes, they are different, distinctive requirements. Clients should provide:

€250,000 investment in qualifying Government Bonds +

Property valued at €270,000/€320,000 or rent of €10,000/€12,000 pa +

Capital of €500,000 and/or €100,000 (arising outside Malta) income per annum.


Q4.5 In regard to €100,000 (arising outside Malta) proof of annual income; is the declaration by the

employer enough?

R4.5 Yes, as long as there is enough information on the employer. Evidence, such as salary slips or contract

of employment showing the annual salary, would suffice.

Q4.6 The guidelines make reference to a Statement of Source of Wealth and Source of Funds. What is

Identity Malta Agency expecting in this regard?

R4.6 The Statement of Wealth and Source of Funds has been incorporated in form MRVP2. Also, a bank

statement of the Applicant’s main account for the last 3 months is also required.

Q4.7 Not many people keep cash in a bank account for a long time; they may have investment in property,

security or business. Can the Applicant present a security/investment portfolio and/or property

appraisal and/or company financial accounts?

R4.7 Yes these documents are acceptable as long as they are issued from a reputable company or an official

entity. These documents will accompany the necessary MRVP forms, including form MRVP2 which

includes the statement of Source of Wealth and Source of Funds. Identity Malta Agency is interested

in the ‘individual’ financial capabilities and the Applicant must convince the Board that he/she has

enough funds to sustain him/herself and dependants. What is important is that reliable evidence is

presented to sustain the Applicant’s declaration.

Q4.8 Who needs to provide proof of income: Main Applicant or also the dependants?

R4.8 Only the Main Applicant is to provide proof of income (€100,000 (arising outside Malta) annually

and/or ownership of €500,000 in kind or in cash).

Q4.9 At which stage does the Main Applicant have to submit an affidavit declaring that he/she has a

sufficient annual income?

R4.9 This declaration is part of the latest version of form MRVP1, which is now considered as an affidavit,

and hence is submitted as part of the application pack.

Q4.10 With regard to the €500,000 capital requirement, would an architect’s appraisal (valuation) be

acceptable as evidence for Identity Malta Agency in order to establish the total net assets of a client if

his/her assets were primarily real estate (and not necessarily cash or other liquid assets)?

R4.10 Yes, an architect’s appraisal is acceptable and real estate can form part of the Main Applicant’s capital

requirement.

Q4.11 Is a spouse considered to be a dependant if he/she has assets or sources of income?

R4.11 Although the spouse is considered as a dependant, nothing precludes him/her from being in

possession of certain assets and of sources of income.


5. The Due Diligence Process

Q5.1 With respect to the “know your customer” evidence and due diligence processes, in which format is

such evidence to be presented to Identity Malta Agency by the RAP/RAA?

R5.1 The RAP/RAA is responsible for introducing reputable Applicants, hence the need to ensure that

RAP/RAA supports Identity Malta Agency by forwarding printed reports with regard to enquiries

conducted from reliable sources on potential Beneficiary and all dependants over the age of 12. Other

information that could be provided by RAP/RAA will facilitate Identity Malta Agency to conduct a

proper due diligence assessment. RAP/RAAs must remember that they should keep evidence of their

investigations, for which they are solely responsible.

Q5.2 At which stage do RAP/RAAs need to submit evidence of KYC and other due diligence processes?

R5.2 These have to be submitted during the application stage.

Q5.3 With respect to the due diligence process which will be initiated once the full documents of the Main

Applicant and his/her dependants have been submitted, may you advise on the time frame of the

aforementioned due diligence?

R5.3 We are anticipating that the full process, which includes the due diligence stage, will be carried out

throughout a period of 3 to 4 months.

6. Checklist of documents to be presented during application submission

Q6.1 Where do I find a list of documents that have to be presented during application submission stage?

R6.1 A list has been introduced in the Application and Documentation Guidelines available on the Identity

Malta Agency website.

Q6.2 Would the department require the original birth certificates, marriage certificates, etc., at a later

stage?

R6.2 No. We require such certificates at application stage and they may be submitted either as original or

certified true copies of originals. These documents should be either apostilled or legalised, as the case

may be. If such documents are in a language other than English these should be translated to English.

Translations done abroad should be apostilled or legalised. Translations done in Malta should be

carried out by a registered translator.


Q6.3 How should an RAP/RAA proceed if the Main Applicant and/or his/her dependants are not able to

obtain a police conduct from a particular country?

R6.3 As per Sections 6.2.a and 7(b) of LN288 of 2015, the first preference is a police certificate issued by

the Malta police as well as a police certificate issued by the competent authorities (federal or national)

in the country of origin and in the country or countries of residence where the Main Applicant has

resided for a period of more than six months during the last ten years. Only in exceptional cases,

where it is proven to the satisfaction of Identity Malta Agency that such a certificate is not obtainable,

we would require an affidavit from a Police Official and/or a Government Entity in his/her country of

origin or where he has resided for a period of more than 6 months in the last 10 years, confirming that

good faith attempts were made by the Applicant to obtain the required certificates. Moreover,

another separate sworn affidavit made by the Applicant and any dependants, declaring a clean

criminal record is required.

Q6.4 In cases where the Applicant has never resided in Malta, is a police conduct certificate issued by the

Maltese police still required?

R6.4 No, it is not required.

Q6.5 Would a Main Applicant need to submit a copy of divorce certificates, signature and copy of passport

of the divorced partner(s) in case of dependent children?

R6.5 In case of a divorced individual – whether a Main Applicant or a qualifying dependant - a divorce

certificate must invariably be submitted.

In the case where the Main Applicant has sole legal custody, there is no need to obtain the signature

of the divorced partner, and a copy of the divorced partner’s passport. The client, in this case, must

provide a court document showing that he/she has sole custody of the child/children.

However, if the Main Applicant has a shared custody of the child/children (dependants), there will be

the need to obtain the signature of the divorced partner on Form MRVP 4 and a certified true copy of

his/her passport.

In the case where the divorced partner has sole legal custody, the Main Applicant can include the child

as his/her dependant if the divorced partner signs Form MRVP4.

Please note that in all the above case the Main Applicant may be replaced by the Spouse. In other

words what applies for the Main Applicant applies for the Spouse.

Q6.6 Apparently, in the case of minors, consent by both parents is required. In this regard, may you kindly

advise which application forms should the parent (who is not part of the MRVP) sign to give his/her

consent for the minor to be part of the MRVP with the other parent?

R6.6 Reference is being made to Form MRVP4 – Declaration of Dependant. In case Applicant has sole custody of the child/dependant, his/her partner is not required to sign any additional papers. This is without prejudice and subject to the national laws in the child’s country of origin. In the case of shared custody the other parent has to fill in Section C and provide a copy of his/her full passport.


Q6.7 Would the RAP/RAA need to submit any documents prior to setting up an appointment with the

Customer Care of MRVP in order to place the application?

R6.7 No, there is no need for any documents prior to setting up an appointment. The RAP/RAA must simply

ensure that all documents stipulated in the guidelines/application forms, are provided to Identity

Malta Agency on submission of application pack.

Q6.8 With regard to the ‘Representation Agreement/Power of Attorney’ to be entered into between

Applicant and RAP/RAA: Does the representation agreement have to be in some particular form?

R6.8 It is at the discretion of the RAP/RAA and the Applicant to agree on the form of the representation

agreement, which is our case has to be a fully fledged Power of Attorney.

The following points must be included in the PoA:

1. Date of POA;

2. Details of Main Applicant i.e. full name, passport number and country of issuance and residing

address;

3. Details of RAP/RAA being appointed attorney i.e. full name, ID Card number and residing

address;

4. Validity to cover the full duration of the application process, from submission to collection of

Residence Certificates and Residence Cards;

5. Signature of Grantor;

6. Signature of Attorney, and

7. Full name and signature, passport number and country of issuance of Witness.

Q6.9 If the Main Applicant confirms that he/she holds share in a company that is publicly listed (that is, it is

a PLC) are company documents to be submitted with the Application Pack?

R6.9 If the Main Applicant’s shareholding exceeds 25% of the total shareholding in a publicly listed

company, the company documents are required.

Q6.10 Is documentary evidence of residential address required only for the Main Applicant or for all adult

dependants, including the spouse?

R6.10 We only need documentary evidence of the Main Applicant’s residential address.

Q6.11 Do expired residence permits need to be submitted together with the valid ones during the submission

of the application pack?

R6.11 No, only residence permits which are still valid at the time of application need to be submitted, for

Main Applicant and all dependants.

Q6.12 What proof would be considered as satisfactory in proving that an adult dependant (child, parent,

grandparent) either of the Main Applicant or his/her spouse, is not economically active and that he/

she is principally dependent on the Main Applicant?


R6.12 The Main Applicant must declare this in an affidavit. It is recommended that any documentary

evidence that corroborates this declaration is submitted with the application pack together with the

affidavit.

Q6.13 In the event that the parent or grandparent, either of the Main Applicant or the Spouse, receives some

form of retirement income, will he/she still remain eligible to be included as a dependant?

R6.13 Yes, they would be eligible. However, the Main Applicant must still provide an affidavit confirming that

the afore-mentioned parents or grandparents are his/her or her dependants.

Q6.14 Is there a specific template for the Affidavit of Dependency?

R6.14 No, there is no specific template. However, it is advisable to make use of the wording found in LN288

of 2015.

7. Questions with regard to the supporting documentation to be submitted with the application forms

and MRVP2, MRVP3 and MRVP4

Q7.1 In accordance with Article 6 (2) (c ) - (f) the Applicant must provide an undertaking to purchase or

lease a qualifying immovable property, to make the qualifying investment in Malta and to remit the

total of the non-refundable contribution. Is the declaration on Form MRVP 1 sufficient or do you

require a separate undertaking executed by the Applicant?

R7.1 The declaration in Part C on the MRVP 1 Form suffices.

Q7.2 Article 6 (2) (f) refers to a certificate requested from a reputable health system to the satisfaction of

Identity Malta Agency. Does Part E of MRVP3 suffice or is a separate certificate required? Also would

you need evidence of the licence/warrant to be provided in relation to the physician examining and

certifying the medical report and questionnaire (Form MRVP3)?

R7.2 Yes, it is covered by Part E of form MRVP3. It is recommendable that a copy of the licence or equivalent, is included with form MRVP3.

Q7.3 Please refer to the qualifications and general requirements mentioned in Article 7 (c ) – (h) of Legal

Notice 288 of 2015, being some of eligibility criteria for the Applicant and dependants. Please advise whether it would suffice if the Applicant and the dependants provide a declaration sworn before a Commissioner of Oaths confirming what is listed in the mentioned sub-articles of Article 7 of the said legal notice or if anything else is required.

R7.3 Part C in the form MRVP 1 and parts A or B, as applicable, in the form MRVP 4 suffices. No additional

requirements are needed unless specified by the MRVP Unit.


Q7.4 A statement of Source of Funds and Wealth is one of the documents which will be required - would an administrative form have to be completed ?

R7.4 No more documents are required as this has been incorporated in form MRVP2. Hence the

information requested in Form MRVP2 should suffice.

Q7.5 Which administrative forms would need to be completed for the Applicant and his/her dependants

upon submission of application pack? R7.5 There are four forms that are required per individual:

The Main Applicant requires: 1. Form MRVP1 (Application form) 2. Form MRVP2 (Personal Details), and 3. Form MRVP3 (Medical Report and Questionnaire) 4. Form MRVP6 (Clearance form)

Each Dependant that is mentioned in the Form MRVP1 (Application form) requires: 1. Form MRVP4 (Dependant Declaration) 2. Form MRVP2 (Personal Details), and 3. Form MRVP3 (Medical Report and Questionnaire) 4. Form MRVP6 (Clearance form) for dependants over 12 years of age on the date of application.

Notwithstanding this, other documents may be introduced in the future, as the need arises. It is imperative that the latest version of these forms are downloaded from our website just before the application process commences.

Q7.6 Please can you confirm if there is a minimum amount of health insurance required for each MRVP

Applicant and dependant?

R7.6 Yes there is. It is €30,000 (thirty thousand Euros) minimum. It is important to submit the endorsement

letter, or equivalent, clearly listing details of cover, including:

1. List of persons insured

2. Minimum cover per person per annum

3. Covers EU countries

4. Validity of cover has to be of a minimum of 1 years, renewable

5. Not a travel Policy

6. Covers full hospitalisation

7. No exclusions in cover

Q7.7 We are in contact with some people in China and they have informed us that notaries in mainland

China do not notarise and apostille documents. Have you encountered this problem/issue? What is

the applicable procedure that is acceptable to MRVP?

R7.7 Yes, we have already encountered similar occurrences. Official documents/notarial certificates

originating in China have to be legalised, meaning that such documents have to be certified by the

foreign ministry of China and subsequently have to be certified by either the Maltese Embassy in

Beijing or the Maltese Consulate in Shanghai. Several Applicants have already done this without

encountering issues.


Q7.8 What happens if the Main Applicant cannot produce a birth, a marriage or a divorce certificate when

applying for residency?

R7.8 We shall accept application however during its processing they would still need to provide such

certificates, or the family book, or equivalent, wherever this is produced. Each case will be dealt with

on its own merits.

Q7.9 Which are the official documents and in which format may they be submitted?

R7.9 Official documents are:

1. Birth Certificate 2. Marriage Certificate 3. Divorce Certificate 4. Passport 5. Police Conduct (Original only is accepted) 6. Military Records 7. Award of Custody

Original Official Documents need to be apostilled/legalised by the government authority of the

issuing country.

A Certified True Copy of an apostilled/legalised original is acceptable. However, if certification is

done abroad, an apostille/legalisaton of the certifier is required.

Translations of original or of certified true copies of these official documents need to be

apostilled/legalised if done abroad.

Q7.10 In which language should a self-declaration be submitted?

R7.10 A self-declaration, has to be signed and dated by the issuer and has to be submitted in original. Any

self-declarations not in English must be translated to English.

Translations done abroad have to be apostilled/legalised. Translations done locally do not need to

be apostilled/legalised but have to be carried out by a Malta registered translator.

Q7.11 Should parents or grandparents applying be above a certain age?

R7.11 No, there are no age threshold.

Q7.12 We assume that evidence of Business ownership is applicable only to the extent that the Main Applicant has declared that he is self-employed. Kindly confirm.

R7.12 In the case of business ownership, whether in part or in full, this is required whatever the declared employment status. Hence this is always required.


Q7.13 Is evidence of employment required when the Main Applicant has declared that he is not self-employed.

R7.13 Evidence of employment is required when the Main Applicant has declared that he is not self-employed.

Q7.14 What evidence would a Main Applicant, who declares that he is both “self-employed” and “not self-employed”?

R7.14 In the case where the Main Applicant is both self-employed and not self-employed, he has to mark both options in Part C of form MRVP2 and has to produce evidence on both his/her employment and his/her self-employment.

Q7.15 How should Form MRVP 4 be completed?

R7.15 In case of minors who are less than 12 years old on the date of application, just the tick box in Part B

and all of part C have to be completed. In the case of a minor dependant who is between 13 and 18

years Part B and Part C have to be completed. In the case of an adult dependant Part A is to be

completed. Part C1 is to be filled in and signed by the Main Applicant or the Spouse, who is to select

in which role he/she is submitting the form by selecting Main Applicant or Spouse in the appropriate

Field. If he/she has sole custody, he/she has to denote this by ticking the box denoting sole

custody. Part C2 is to be filled in by the other parent/legal guardian of the minor unless the other

parent has sole custody. Again, this person (other parent/legal guardian) has to tick whether he/she

is the Main Applicant, the Spouse or a Non-Applicant in relation to the minor whose details are

written on the form.

Q7.16 Is it only Form MRVP1 which requires the signature of the Commissioner for Oaths?

R7.16 The MRVP1 is a sworn/affirmed declaration and therefore has to be signed in front of a Commissioner for Oaths (or whoever is empowered to administer oaths in the respective jurisdiction), who has to stamp, sign and date the form. Moreover, both the Main Applicant and the Commissioner for Oaths have to initial each page.

Q7.17 On the Form MRVP3 (Medical Report and Questionnaire), if a specific hospital/doctor fills in and signs

the form, do they still have to supplement a medical test report

R7.17 The form should suffice as long as it is accompanied by the patient’s identification document which is

stamped, signed and dated by the examining physician.

Q7.18 Which hospitals are accepted by the Maltese authority? If international hospitals are accepted and

the client has the examination record in English, is an apostille from the Maltese Embassy required?

R7.18 National and international hospital are accepted. There is no need for an apostille.


Q7.19 When there is no Maltese Embassy or Consulate in a certain country, or if the Main Applicant so

desires, can a local lawyer/solicitor/notary be the witness for the signature on Form MRVP1 and any

other affidavit? Also, can a local Court be the witness of the signature?

R7.19 Whoever is empowered to administer oaths in the respective jurisdiction, and we have official

confirmation that this is the case, can witness the signature on Form MRVP 1 and other affidavits. A

commissioner for oaths could also be available in local Courts of Law. It is to be remarked that all

signatures should bear the stamp of office and any other relevant details.

8. Submission of application

Q8.1 Would the Main Applicant need to be present when the application is submitted?

R8.1 No. The RAP/RAA will submit the application on behalf of the client.

Q8.2 How would the initial €5,500 be settled?

R8.2 The €5,500 have to be transferred via an electronic bank transfer into account number 40023969188

in the name of “Identity Malta Agency” with Bank of Valletta plc. At the time the application pack is

accepted by IMA, a request for payment is handed over to the RAP/RAA, who is to affect payment

within 3 working days, quoting IMA Application Reference number.

Q8.3 What would you consider an appropriate agreement with the RAP/RAA; would a copy of our

company’s standard “Letter of Engagement” suffice as proof for this purpose?

R8.3 IMA does not need a copy of the “Letter of Engagement”. What is actually required, is a valid Power

of Attorney clearly granting the rights to the Attorney to handle the application until the date of the

finalisation of the relevant application process.

Q8.4 Does Identity Malta Agency require any specific format for the submission of the application, including

referencing, etc?

R8.4 Yes, please follow the Recommended Filing Order in the Application and Documentation Guidelines

found on Identity Malta Agency Website

Q8.5 A19 of form MRVP2 refers to ID card details of issuing country. Is a copy required with the application

(translated, certified, apostilled)?

R8.5 Yes: it has to be a certified true copy and translated if not in English. Moreover, if translations are

done abroad these need to be apostilled/legalised. Translations done in Malta should be carried out

be a certified translator.


Q8.6 With regard to dependants; is the affidavit of dependency the only requirement as proof of

dependency or is any additional proof/supporting documentation required? For instance: school

certificates, certificate of retirement, etc?

R8.6 The affidavit of dependency should suffice but any evidence would facilititate the process.

Q8.7 Are there any guidelines on the fees which RAP/RAAs should be charging in connection with their

services for the purposes of the Malta Residence and Visa Programme?

R8.7 It is at the discretion of the respective RAP/RAAs/individuals to decide which fees to charge their

clients.

Q8.8 The RAP/RAA has to provide a covering letter stating why the Main Applicant is interested in obtaining

residence in Malta. Why would the client not be doing this in the form of a Letter of Intent, as they do

in the other programmes? Also, in the checklist they make reference to a covering letter being signed

by the RAP/RAA. Would this not be the usual cover letter we hand to you to sign, as the description

matches what we would usually know as the Letter of Intent?

R8.8 We require an introductory letter of the prospective Applicant from the RAP/RAA. The Main Applicant

may also opt to forward a letter of intent.

Q8.9 Can the RAP/RAA submit one marriage certificate per couple as we do in the IIP programme, rather

than one from each married person? With regard to divorce certificates, do they have to be provided

all or do the most recent ones suffice?

R8.9 There is no problem with producing one marriage certificate (or a certified true copy) for a wedded

couple. In our case we need all divorce certificates.

Q8.10 Is a written signed declaration from the client adequate? Or do they have to submit an affidavit?

R8.10 In certain cases a written signed declaration is needed, as in the declaration of wealth/income, for

example. In other cases, and this is specifically stated, an affidavit is required, for example, when Main

Applicant declares that the dependants over 18 years are economically dependent on him/her.

Q8.11 Affidavits – Is a Commissioner for Oaths a suitable person to attest to the signature of the affiant?

R8.11 Yes, the Commissioner for Oaths is a suitable person for this function.


9. Issuance of Letter of Approval In Principle, Residence Certificate, Biometrics and issuance of

Residence card

Q9.1 What will happen once the application packs are submitted by the RAP/RAA?

R9.1 A receipt of the application pack is given to the RAP/RAA who is also requested to pay the initial fee

of €5,500. Once these are received by IMA, a due diligence exercise on the Main Applicant and

dependants is done. If this is successful, the Letter of Approval in Principle is issued by the MRVP

team. Following this process, which will take 4-5 months, the Main Applicant will need to buy/lease

the Qualifying property, buy the Qualifying Investment and purchase the necessary Health Insurance

Cover. The Main Applicant will be allowed a timeframe of three months (we can extend as the need

arises) from the receipt of the Letter of Approval in Principle. Once the Main Applicant provides all the

documentation, IMA will issue a letter of invitation to the Main Applicant (AKA beneficiary), inviting

him/her and his/her dependants to call at our offices for the capturing of biometric data. With 3 to 5

days IMA will issue the Residence Certificate and Cards.

Q9.2 Will the Residence Certificate and the Residence Card have expiry dates?

R9.2 As long as all requirements stipulated in LN288 of 2015 will continue to be met, the Residence

Certificate will not have an expiry date and the Residence card, which will reflect the said immigration

position, will be initially valid for a period of five years, renewable. In cases where a Residence Card

is issued to a minor of less than 14 years, and the minor turns 14 within the “normal” 5 year card

validity, the expiry date of such minor’s card, will fall due one month after his/her 14th birthday. The

same applies when dependant turns 18 years of age.

Q9.3 Is there any exemption from submitting the biometrics, for instance if a person is a baby or disabled?

R9.3 Yes, children are exempt from biometrics up to the age of 6. However form ID2 together with 2

certified passport size photos need to be submitted for each child. With regard to people with

disabilities, each case will be decided on its own merits.

Q9.4 Will a language test be carried out to test the Main Applicant’s and the dependants’ knowledge of

Maltese/English?

R9.4 No.

Q9.5 Upon renewal of Residence Card after 5 years, do other fees apply?

R9.5 Yes. Each individual has to pay €27.50 per year to have the Residence Card renewed.

Q9.6 Following the initial five year period, upon renewal of residence card, are the Main Applicant and other

beneficiaries required to come to Malta to retake their biometrics?

R9.6 Although 3 sets of biometric data are captured for each Applicant, thus having 2 extra sets in file, the

extra sets might be used up in case of technical issues, and/or in case of a change of address and/or

in case of a loss of card during the validity of the card. In such circumstances, Applicant and/or his/her

dependants will be required to come to Malta for biometric data capturing. In cases where a


Residence Card is issued to a minor of less than 14 years, and the minor turns 14 within the “normal”

5 year card validity, the expiry of such minor’s card, will fall due one month after his/her 14th birthday.

In such a case, another set of biometric data will be used. The same applies when dependant turns 18

years of age.

Q9.7 Would Identity Malta Agency support or facilitate the issuance of visas for Applicants for travelling

purposes?

R9.7 Identity Malta Agency can only provide support through the Central Visa Unit after the Letter of

Approval in Principle has been issued.

Q9.8 Will the commencement of lease need to be as close to Identity Malta appointment as possible?

R9.8 Ideally the Lease Agreement should commence closest to the submission of the final proofs. The

same applies to the Health Policy.

Q9.9 Is the health policy required to be submitted together with other requirements once an application

has been approved?

R9.9 Yes, the Health Policy endorsement, or its equivalent, has to be submitted .

Q9.10 After acceptance of the application, where do the Applicants have to provide the Biometric data? Does

the whole family have to travel to Malta?

R9.10 After the letter of invitation, the Main Applicant and all dependants have to travel to Malta to have

their Biometric data captured. However, at the discreton of IMA and given certain conditions,

Biometric data capturing can also be done in China. In the latter case, Main Applicant and Dependants

would have to travel to Malta to collect their residence cards.

10. Period outside Malta during the 5 years of benefitting from an MRVP residence permit

Q10.1 How will Beneficiary and dependants show that they have been away from Malta for the stipulated

period?

R10.1 Identity Malta would need an annual (in the case of the first five years) declaration from the Beneficiary that states that he/she and all dependants are complying with this requirement when submitting Form MRVP5 - Official Compliance Form.

Q10.2 Can a foreigner ever apply for the acquisition of Maltese Citizenship by naturalisation?

R10.2 Yes, a foreigner may submit an application for the acquisition of Maltese Citizenship by naturalisation

after continuously residing in Malta for a period of five years. He/she should have resided in Malta

throughout the twelve months immediately before the date of application and four years out of the


preceding six year period. He has to be knowledgeable in spoken/written English & Maltese, of sound

mind and of good conduct.

The Minister has the discretion, according to the Law, to grant or refuse the application. It does not,

therefore, mean that if such a person satisfies the said conditions he/she would be automatically

granted citizenship by naturalisation. The Minister’s decision is based on internal policies, whereby

amongst other requirements, the number of years could also be a feature in the examination of the

relative request.

Q10.3 Is a minimum presence required in Malta on the part of the Applicants? Are no days spent in Malta

allowed?

R10.3 There is no minimum presence required.

11. Licence of employment

Q11.1 May a Beneficiary under the programme be granted an automatic licence to be employed or to engage

in business in Malta in view of the provisions of Article 11 of the Immigration Act?

R11.1 No, LN 288 of 2015 does not entitle the Beneficiary to any employment licences. Beneficiary still needs

to apply for a work permit.

Q11.2 How can the Beneficiary and/or dependants apply for a work permit?

R11.2 As things stand today the dependants, except the spouse, cannot be economically active to retain

residency rights under the MRVP. The Beneficiary and the spouse can apply for a work permit by

submitting an application for a ‘work permit’ through the normal channels.

Q11.3 How can the Beneficiary and/or dependants apply to set up a business in Malta?

R11.3 The Beneficiary or spouse can apply, through the competent authorities, to launch a business in Malta,

as long as they satisfy the prevailing legislation. A dependant can also take this route but, if the

application is accepted, he/she would lose his/her status as dependant under the MRVP as he/she

would no longer be economically inactive.

Q11.4 Taxation of working clients: I found information about “a flat tax rate of 15% on foreign source income

remitted to Malta and 35% on Malta source income”. What does this mean please?

R11.4 This Programme doesn’t carry any tax grants and/or incentives. The statutory tax applies and it is

recommended to seek the advice of a tax consultant .

Q11.5 Would a minor dependant of an Applicant be entitled to free education whilst residing in Malta? If so,

does this apply also to Secondary and Tertiary (i.e. University) education?


R11.5 No, under the MRVP a minor is not entitled to free education. However, if the Main Applicant acquires

a work permit, his/her children would be entitled to free primary and secondary education in state

schools.

Q11.6 Can Applicants work in an EU country under the MRVP?

R11.6 The MRVP does not grant the Beneficiary any employment rights in the Schengen Area. Therefore, he

or she will need to apply for a work permit in the Schengen country according to the provisions of the

particular country.

12. Travel

Q12.1 Will the holder of the residence card be allowed to travel Visa free throughout Europe or only in

Schengen countries?

R12.1 Holders of the MRVP residence card may only travel to Schengen countries and for a maximum period

of 90 days within a 180 day period. The traveller should invariably carry a valid travel document.

13. Change in status of a person benefitting from the MRVP

Q13.1 Once a dependant reaches his/her 27th birthday, does that dependant automatically lose his/her right

of residence in Malta? Would the said dependant be required to, on or before reaching the age of 26

years, apply for an MRVP in his/her name?

R13.1 Yes, when reaching 27 years of age the dependant concerned will lose his/her residence status even

if he/she continues to be a dependant of the Beneficiary. If he/she satisfies the conditions of the

programme as a Beneficiary in his/her own right, he/she may submit a separate application. He/she

may do so prior to his/her 27th birthday provided that he/she relinquishes his/her right of residence

as a dependant. If he/she is unable to meet the conditions of the programme, any request to remain

in Malta shall be considered on the merits of the case and in accordance with national rules and

policies prevailing at that time.

Q13.2 When minor children under MRVP reach the age of 18, do they lose their Malta residence status?

R13.2 No, they do not lose their MRVP residence status as they still qualify until they are 27 years old as long

as they satisfy the regulations of the LN288 of 2015.

Q13.3 If a Beneficiary decides to give up his/her residence right in Malta within the first 5 years and move to

another country, can he/she then sell the bond immediately, or does he/she have to wait for 5 years

until he/she can sell the bond? Same question applies to the rental agreement: If he/she wants to

leave Malta before the lapse of the first 5 years, can he/she then get out of the rental agreement or

does the rental agreement have to be for a five period? In our view, this can be done but naturally this

will result in the cessation of the certificate.


R13.3 The fact that he/she sells the bond and does not adhere to the qualifying property agreement, the

client will automatically lose his/her status and this applies vice versa, that is, if he/she relinquishes

his/her certificate, there will be no obligations to fulfil. If a Beneficiary relinquishes and/or loses

his/her residency rights, any dependants benefiting from residency rights through the same certificate

will automatically lose their residency rights.

14. The Official Compliance Form (MRVP 5)

Q14.1 What is the Official Compliance Form (MRVP 5) that is referred to in the Guidelines?

R14.1 The Official Compliance Form (MRVP 5), which is referred to in the Guidelines, is an official form that

the Beneficiary will have to fill-in once a year for the first 5 years, and once every 5 years thereafter

and the RAP/RAA being responsible for the submission of such form. The OCF is in itself a declaration

that the clients’ obligations are being satisfied according to regulations. This form has to be filled in

and signed by the Beneficiary. The RAP/RAA’s responsibility is to ensure that this form is timely

provided to MRVP together with all the supporting documentation. The RAP/RAA has to sign this form

is for collection and administration purposes only.

Q14.2 What will the renewal process for the residence cards be? To what extent will the RAP/RAA be

involved?

R14.2 Residence cards will be issued for a validity of 5 years, unless the minor dependant turns 14 or 18 year

old, in which case the card validity ceases on the dependant’s birthday. In the latter cases, the card is

renewed automatically, free of charge. Renewal requests for the “normal” 5 year expiry, have to come

from the RAP/RAA, as long as the beneficiary continues to comply with the regulations of LN288 of

2015 accordingly.

Q14.3 Will the duration of lease have to correspond with the residence card? I.e. if residence is issued for 5

years, will a client require a 5 year lease?

R14.3 Preferably for a duration of five years notwithstanding yearly renewals are acceptable as long as a

copy of the renewal of lease is attached with the MRVP5 (OCF).

Q14.4 After 5 years, Beneficiary will need to submit the Official Compliance Form every 5 years, to show that

he or she is still fulfilling the obligations. Do all obligations need to be retained? Is there any fee to be

paid? Is there any documentation that needs to be filled and submitted?

R14.4 After five years your client doesn’t need to retain the qualifying investment nor the qualifying

property. The same applies for the EUR500,000 capital and/or the EUR100,000 income per annum.

Notwithstanding, he/she is required to provide us with a suitable residential address to re-issue the

respective residence card.


15. Commission to Concessionaire

Q15.1 Can an RAP/RAA introduce an Applicant who is a national of a country which forms part of a

concession?

R15.1 RAP/RAA may introduce Applicants from any country, even if a concessionaire has been awarded the

concession of the Applicant’s country.

Q15.2 If the Applicant comes through an RAP/RAA and not from the concessionaire, will the concessionaire

be granted a commission from the Applicant’s contribution or will Identity Malta/the Government

keep the whole investor contribution and not distribute any amount to the concessionaire, because

he did not introduce the Applicant?

R15.2 The Concessionaire is still entitled to a commission if and when a client in the Concessionaire’s region,

referred by an RAP/RAA, acquires the relevant residence certificate.

16. Clients who change programmes

Q16.1 If an MRVP Beneficiary decides to change to the Malta Individual Investor Programme (IIP), will the

€30,000 contribution be deduced from the IIP fees ?

R16.1 No. The €30,000 fee paid for MRVP is non-refundable and non-transferable.

Q16.2 Can a client change his/her IIP application over to the MRVP? As yet, the client has not submitted his

IIP Citizenship application, however he has already obtained his/her 18 month residence card via the

IIP.

R16.2 Yes, as long as the full MRVP process will be followed. All MRVP fees contemplated in LN288 of 2015

will remain in force.

Q16.3 If an Applicant already holds a residence permit through another scheme but wishes to apply for the

MRVP, would he still be required to submit new residence forms i.e. Form K, Form ID 1A & Form

ID 2?

R16.3 Yes the Applicant would be required to submit new residence application forms to MRVP. The

Applicant’s documentation submitted for previous permits should have no bearing on the MRVP

application.

17. General questions

Q17.1 Is there a compulsory minimum length of stay within one year after a Beneficiary gets his/her

residence permit

R17.1 No, there is no minimum length of stay requirement.


Q17.2 Can the Beneficiary add dependants at a later stage?

R17.2 Yes the Beneficiary may add dependants at a later stage however, the exact terms and conditions are

still under review.

Q17.3 Is there a fee for the Residence Card?

R17.3 Yes. It is €27.50 per person per annum or part thereof. Hence a card valid for 5 years carries a fee of

€137.50.

Q17.4 What would the consequences be should the Beneficiary divorce from his/her spouse?

R17.4 In the case of a divorce, the Spouse of the Beneficiary will lose residence rights. This might also effect

the Spouse’s children whose other biological parent is not the Beneficiary and who would have been

included as Dependants under the said Application. Each case will be assessed on it own merits.

Q17.5 We have a client who is an EU national, and his/her partner is a third country national. Our client

wishes to apply for the MRVP for his/her partner. In this regard, since our client is of a European

nationality, thus prohibited from applying for the programme, may his/her partner (third country

national) apply for the MRVP and our client acts as her Benefactor?

R17.5 Our legislation does not impede her from submitting an application as a Main Applicant, supported by

a Benefactor.

Q17.6 Can there be a Benefactor under the MRVP?

R17.6 Yes, there can be a Benefactor under the MRVP.

The required documents for a Benefactor are the following:

- Form MRVP2, in the name of the Benefactor, fully completed (all sections including the Source of Funds and Wealth Part); - Part A of form MRVP 4, in the name of the Benefactor;

- 3 month Bank Statements for the Benefactor’s account from which the funds for the MRVP

application will be remitted (i.e., transferred to Identity Malta);

- Certified true copy of all valid International Passports of the Benefactor(ALL pages);

- Evidence of Current Employment (if applicable);

- Evidence of Business Ownership (for business owned in part or in whole by the Benefactor);

- Sworn declaration that the Benefactor will fund the MA’s MRVP application and all the related

financial obligations, and will also provide the MA with stable and regular resources.

The Main Applicant should still complete Form MRVP2 in its entirety and provide a 3 month bank

statement of his/her personal bank account.


Q17.7 Can an adult dependant who is employed and receiving the minimum wage still be supported by the

Main Applicant where the minimum wage is not enough to support their lifestyle?

R17.7 By legal definition, the answer is no. A dependant has to be economically inactive.

Q17.8 Can the residence card be renewed abroad through the Maltese Embassy?

R17.8 As things stand today the Residence Card cannot be renewed through a Maltese Embassy.

Q17.9 In Form MRVP3, Part A, the Applicant needs to list the Licenced medical practitioner, is it correct to

assume that this is the usual General medical practitioner?

R17.9 Yes.

Q17.10 In Form MRVP3, Part D needs to be filled in by the examining practitioner. Who can this be?

R17.10 This may be the same General Medical Practitioner who filled in Part A of MRVP3. However, it could

be a different Medical Practitioner.

Q17.11 Is a health certificate issued by a hospital in Russia accepted? (On this matter the legislation provides

that certificate is to be issued by a reputable health system to the satisfaction of Identity Malta)

R17.11 Yes, as long as the certificate is signed, dated and stamped by the Medical Practitioner. The Medical

Practitioner should also include his/her professional license number, where applicable.

Q17.12 Is there a particular wording which the health certificate must contain?

R17.12 The wording is at the discretion of the GP/Medical institution.

18. Address of MRVP Offices for Applications, Appointments, Biometrics and Issuance of Residence

Cards

Q18.1 Which Identity Malta department are the applications to be submitted to?

R18.1 Applications are to be submitted at: Identity Malta, MRVP, Clock Tower, Level 1, Tigné Point, Sliema

TP 01, Malta.

Q18.2 Where will appointments and biometrics be taken?

R18.2 Appointments and Biometrics will be exclusively handled from the same location i.e. Identity Malta,

MRVP, Clock Tower, Level 1, Tigné Point, Sliema TP 01, Malta.


Q18.3 From where will residence cards be issued and from where can they be collected?

R18.3 Residence cards will be issued and can be collected from the same location i.e. Identity Malta, MRVP,

Clock Tower, Level 1, Tigné Point, Sliema TP 01, Malta.