Malta has updated its Labour Migration Policy, with new rules being rolled out in phases from August 2025. The focus seems to be shifting from simply increasing foreign worker numbers to hiring based on specific skill sets.

For businesses, this means tighter compliance requirements. Employers will face stricter obligations and tougher penalties under the new framework.

The main goal is to prevent exploitation, protect the rights of TCN workers, and reduce unnecessarily high staff turnover. The new system aims to match foreign hiring more closely with real workforce needs, while ensuring a level of fairness throughout the recruitment process.

The New Hiring Process for TCNs

The Mandatory Labour Market Test (LMT)

As of October 2025, the Labour Market Test will become mandatory. Employers must advertise the vacancy on both the Jobsplus portal and the European EURES portal for at least three weeks.

If any Maltese or EU nationals apply, employers need to provide Jobsplus with a clear, well-documented explanation of why those candidates aren’t suitable. The process can only continue once Jobsplus accepts this justification.

The Single Permit Application

After passing the Labour Market Test, the employer submits the Single Permit Application through Identità’s official portal. This step requires supporting documents, including the signed contract, proof of accommodation, and either MQRIC recognition of the applicant’s qualifications or reference letters. If the applicant does not hold the required qualification, at least three years of relevant work experience must be demonstrated through reference letters.

The main players here:

  • The Employer: handles the application and documentation
  • Jobsplus: manages the Labour Market Test and employment registration
  • Identità: issues the final residence and work permit

Managing Application Timelines and Expectations

Processing times can be lengthy because several agencies - Immigration Police, Jobsplus, and Identità - are all involved, each with its own administrative steps. With these new checks in place, you should expect longer approval timelines.

If you’re hiring a TCN, set clear expectations with both candidates and internal teams about how long the process can take. At Konnekt, we see that applications for candidates classified as “Still Abroad” usually take the longest; in the past, these could stretch to eight months, though the average is now between 60 and 90 days.

For urgent or high-value roles, we recommend considering the Specialist Employee Initiative (SEI) or Key Employee Initiative (KEI). These applications move faster as both schemes are aimed to attract and retain skilled Third Country Nationals.

Conversely, be aware that applications for roles with salaries under €30,000 gross may face slower processing times, and you should factor this potential delay into your recruitment planning.

Understanding Common Pitfalls and Rejection Grounds

LMT Challenges: Market Saturation and High Turnover

Jobsplus closely monitors TCN termination rates at each company. If your company exceeds the new thresholds for ending TCN contracts, you may be blocked from recruiting new foreign workers. Jobsplus also regularly reviews labour market demand, and may reject applications if their assessment shows no current need for certain positions. For example, since mid-2024, renewals for delivery driver permits have faced a high rejection rate, with authorities citing an oversupply of drivers and no further need for TCNs in that role.

Core Documentation

Starting in 2025/2026, work permit applications for TCNs require strict compliance with a mandatory documentation checklist. This includes proof of comprehensive health insurance, a full copy of the applicant’s passport, and a registered lease agreement for accommodation.

A key focus is the recognition of the applicant’s qualifications by the Malta Qualifications Recognition and Information Centre (MQRIC). However, if the applicant does not hold the required qualification, at least three years of relevant work experience can be shown through reference letters instead.

Practical Advice for Hiring Managers

When hiring for technical or skilled trade roles, plan ahead and set realistic expectations. There is still no clear system in Malta for getting foreign trade certificates formally recognised by MQRIC, which makes the process difficult.

For example, in trade professions like electricians, there’s currently no infrastructure that allows for the recognition of foreign trade certificates or licenses. Even if a license like “Electrician Licence A” aligns with Malta’s basic single-phase standards, candidates must still go through equivalency validation and pass local assessments. This can pose significant hurdles, especially for those from non-EU countries. To legally perform electrical work in Malta, one must obtain this license from the Regulator for Energy and Water Services (REWS). This involves passing a Maltese-administered examination (Wireman Exam), providing documentation of relevant work experience (12 months under supervision for Authorisation A), and additionally, undergoing an interview, presenting a medical declaration, a police conduct certificate, and demonstrating competency in English or Maltese.

Other Critical Compliance Checks

Applications will be automatically blocked if a company is not compliant with the Persons with Disability (Employment) Act.

In addition, TCNs who arrive in Malta on a tourist visa are now generally ineligible to apply for a work permit while in the country. This rule has been established to reinforce compliance and ensure only eligible candidates can proceed through the process.

Updated Permit Types and Salary Thresholds for TCNs

Key Permit Categories and Salary Thresholds

To attract high-value talent, Malta has raised the salary and role requirements for its specialised, fast-track permit categories. The Key Employee Initiative (KEI) targets highly skilled managerial or technical professionals and now requires a minimum annual gross salary of €45,000.

For other qualified technical and professional roles, the Specialist Employee Initiative (SEI) is available, with a new minimum salary threshold of €30,000 per year. The EU Blue Card remains an option for highly qualified TCNs, with a salary benchmark set at 1.5 times Malta’s average annual gross salary. The standard Single Permit is still the main route for other eligible full-time roles, all of which require passing the Labour Market Test.

Strategic Permit Selection and Renewals

Choosing the right permit depends on the candidate’s salary, formal qualifications, and the nature of the job. For renewals, both TCNs and employers must meet the same strict compliance checks as in a new application. If a TCN wishes to switch employers, this triggers a new application process - the new employer must complete and pass a new Labour Market Test before the employee can legally transfer.

New Employer Obligations: Ensuring Compliance and Reducing Risk

Key Day-to-Day Compliance Tasks

The new policy introduces a much heavier compliance load for employers. One of the key changes is that, starting in October 2025, all salaries for newly registered TCNs must be paid electronically through a licensed financial institution. This shift aims to increase transparency and help prevent abuse.

Employers are now required to meet strict administrative deadlines as well. All Jobsplus engagement and termination forms must be submitted within four working days of the event. On top of this, companies are expected to keep TCN turnover rates low; consistently high termination rates can result in a ban on future recruitment.

Significant Financial and Recruitment Risks

These new requirements bring real compliance risks for employers. Failing to meet the legal quota for employing persons with disabilities, or missing the deadline for submitting forms, can immediately suspend all new TCN applications.

The government has also raised fees and penalties: the cost for a new Single Permit application has doubled from €300 to €600. In addition, a new quota system will limit the number of TCNs a company can employ based on its total workforce size - a change that will especially affect new businesses looking to hire foreign staff.

Proactive Strategy is Key to Success

Hiring TCNs in Malta now means dealing with three major changes: the mandatory Labour Market Test, higher salary thresholds for specialised permits, and stricter employer obligations. Success under this regime requires proactive compliance and careful workforce planning.

To manage these changes, use the official digital portals provided by Maltese authorities. The Identità website is the main platform for submitting Single Permit applications, while the Jobsplus portal is used for the Labour Market Test and employment registrations.

With regulations becoming more complex and enforcement stricter, many employers are working with professional HR and recruitment firms like Konnekt.

Partnering up with Konnekt and Konnekt Payroll means you can trust that everything from recruitment to documentation to Labour Market Test requirements will be sorted, keeping your business fully compliant with Malta’s new migration regulations.

Want to make your hiring process smoother and stay ahead of changing rules? Get in touch with us today to see how we can help your business stay on track.

About the author: Avinash Ajay is a Global Sourcing Specialist with more than 8 years of experience hiring third-country nationals. He has placed over 1,000 professionals in different industries and helped companies in Malta build strong teams.