Malta has taken another significant step in strengthening the regulatory integrity of its maritime register. On 30 January 2026, Transport Malta’s Merchant Shipping Directorate issued a new Code of Standards for the Appointment and Responsibilities of Resident Agents (the “Code”).The Code introduces a more structured and formalised framework governing Resident Agents appointed by International Owners under Malta’s Ships Eligible for Registration Regulations. It consolidates regulatory expectations in areas such as sanctions screening, due diligence, ownership transparency and ongoing monitoring, reinforcing Malta’s alignment with evolving international compliance standards.
For Resident Agents and International Owners alike, the message is clear: compliance expectations are becoming more structured, documented and continuous.
Formalised and Ongoing Sanctions Screening
A central feature of the new Code is the formalisation of ongoing sanctions screening responsibilities.
Resident Agents are now expressly required to maintain effective and continuous sanctions screening systems covering:
- International Owners
- Shareholders
- Directors
- Ultimate beneficial owners (UBOs) where applicable.
Any matches, risks or instances of non-compliance must be immediately reported to the competent Maltese authorities , with appropriate action taken without delay.
Strengthened Governance in the Resident Agent Relationship
The Code places significant emphasis on governance and clarity in the relationship between the Resident Agent and the International Owner.
Resident Agents must ensure that:
- Communication protocols are clearly defined
- Authorised contacts for official requests and submissions are formally identified
- Structured procedures exist for appointment, replacement and termination
- A contingency process is in place where contact with the International Owner is lost.
Importantly, the Code also requires that the International Owner’s obligations are clearly defined. These include timely cooperation and indemnification of the Resident Agent. This ensures that Resident Agents are properly positioned to discharge their statutory duties without operational or legal uncertainty.
The emphasis on governance reflects a broader regulatory trend toward accountability and clearly documented operational framework.
Enhanced Documentation Requirements
The Code introduces detailed documentation requirements that must be satisfied prior to appointment and retained for at least five years from the date of collection. Crucially, the information obtained must remain accurate, complete and continuously updated.
More stringent obligations apply in specific higher-risk scenarios, including where:
- the International Owner is a non-EU/non-UK legal person owning or intending to own a pleasure vessel of 24 metres or more; or
- the International Owner is established in a jurisdiction listed on the EU Sanctions Map and owns or intends to own any vessel of 24 metres or more.
In such cases, Resident Agents must obtain comprehensive corporate and ownership documentation, including:
- Constitutional documents,
- Official company registry extracts,
- Detailed ownership structure charts identifying UBOs,
- Declarations from directors
- Identification and proof of address for UBOs.
Even where not strictly mandatory, the Code recommends applying enhanced standards as best practice to International Owners established outside the EU or UK.
For International Owners who are natural persons, a valid identification document and evidence of residential address is considered sufficient.
The Registrar General of Shipping and Seamen is also expressly empowered to request enhanced due diligence at any time, reinforcing the supervisory authority’s discretion in higher-risk situations.
Annual Directors’ Declaration
To ensure ongoing transparency, the Code introduces an annual confirmation requirement for the legal person International Owners.
Every twelve months, Resident Agents must collect an Annual Directors’ Declaration confirming that no changes have occurred to the company’s structure, ultimate beneficial ownership, or control. Where changes have taken place, these must be notified without undue delay, and supporting documentation may be required.
This annual certification mechanism introduces a structured compliance chekpoint, ensuring that ownership transparency is not treated as a one-time onboarding exercise but as a continuous obligation.
Practical Implications
The introduction of the Code signals a shift toward more formalised, risk-based compliance management within Malta’s maritime framework.
Resident Agents should:
- Review and, where necessary, upgrade sanctions screening systems
- Formalise internal onboarding and documentation procedures
- Implement tracking mechanisms for annual directors’ declarations
- Ensure ownership structure documentation remains current and verifiable
International Owners, in turn, should anticipate more detailed due diligence processes and ongoing compliance requests, particularly in higher-risk ownership structures or jurisdictions.
Early preparation and clear internal governance structures will be essential to avoid delays in vessel registration or ongoing administrative processes.
Reinforcing Malta’s Regulatory Standing
The new Code further strengthens the Malta Flag’s reputation as a transparent, internationally aligned maritime register. By codifying expectations around sanctions monitoring, beneficial ownership transparency and governance standards, Transport Malta has reinforced its commitment to regulatory integrity in an increasingly scrutinised global environment.
For stakeholders operating under the Malta flag, the Code represents not merely an administrative update, but a clear signal that compliance must be structured, documented and proactive.
