The curse of the NEW Maltese citizenship by merits program
On 29 April 2025, the European Court of Justice ruled that the Maltese citizenship by investment program violated EU law. This decision effectively ended the Maltese Golden Passport scheme. In July 2025, Malta was forced to change its legislation to follow the court ruling. Soon after, the Maltese Parliament introduced its new citizenship for merit program. The framework looks more refined and carefully drafted, taking into consideration the ECJ ruling. However, virtually everyone, including the European Commission, see the new citizenship by merits legislation as a renamed version of the old investment program. And this creates potential risks for future citizens who obtain Maltese passports through the special merits route.
See how does the Maltese merit citizenship compares to the Bulgarian citizenship for special merits program.
Maltese citizenship by merits – no access to EU banking?
EU Banks are quite picky when it comes to opening bank accounts to non-residents. And what we already hear from the banks is that they will be extremely cautious if they are to open an account for naturalised Maltese citizens. Specifically for those, who have acquired their passports through the new citizenship by merits program. Banks in the EU are afraid of doing business with anyone who seems to be a “non-regular” customer. And the banks already know that all new Maltese citizens have most probably acquired their citizenship through the controversial special merits program.

Maltese citizenship by merit – a red flag for the banks in Europe
You may wonder how EU banks will know that you obtained your Maltese citizenship through the special merit route. If you were born outside Malta, banks will immediately assume that you are naturalised. This often suggests that you received citizenship for special merits. Or even worse, through the old investment program – ruled to be unlawful by the European Court of Justice. During the bank account opening process, you must also declare any additional citizenships. Once you list your other (original) citizenship, it again becomes clear that your Maltese citizenship is acquired, almost certainly, not by birth.
And what if you already have an account with an EU bank
If you already have an EU bank account and plan to obtain Malta citizenship for special merits, think carefully. Banks in the EU must update client information at least once a year. During this routine check, you will be asked to confirm your latest personal data. At that moment, you will need to report your new Maltese citizenship. This is the point when the bank may restrict your access to services or, in some cases, even freeze your account.
The Maltese citizenship for special merits remains an appealing option for those willing to accept certain risks
Please don’t think we are trying to discredit the new citizenship for merits program introduced by Malta. On the contrary, we believe it is a unique opportunity for many ultra-high-net-worth individuals who want to obtain an EU passport. Our goal is simply to warn potential applicants that along with a new Maltese passport, they may lose access to EU banking. This risk is real, and everyone should carefully consider whether it is worth taking.
As always, should you have any questions or remarks, please don’t hesitate to contact us.









