31/08/2026
CSPs in Malta: the new HRRF is worth reviewing now, not when reporting is due.
The Malta Financial Services Authority (MFSA), in collaboration with the Financial Intelligence Analysis Unit (FIAU), has published draft technical documentation for the Harmonised Regulatory Reporting Framework (HRRF).
For CSPs, this is a good time to look beyond the reporting template and review how the information behind those returns is currently maintained.
So what should CSPs be looking at now?
✅ Review the draft reporting requirements.
Understand what information will be required and how it will need to be submitted.
✅ Identify where that information currently sits.
Consider whether the required data is held across client records, entity information, compliance records or other systems.
✅ Look for gaps or inconsistencies.
Check whether information is complete, maintained consistently and readily available when reporting is required.
✅ Clarify ownership internally.
Who maintains the underlying information? Who reviews it? Who will be responsible for preparing and approving the submission?
✅ Prepare for the CSP seminar on 15 September.
The MFSA and FIAU session will cover the new documentation and data structure, submission process, timelines and questions from the sector.
Official CSP HRRF documentation and resources:
https://www.mfsa.mt/our-work/company-service-providers/
CSP HRRF seminar, 15 September 2026:
https://www.mfsa.mt/events/hybrid-seminar-on-the-implementation-of-the-harmonised-regulatory-reporting-framework-hrrf-for-company-service-providers-csps/
The practical point is not simply that reporting requirements are changing.
As regulatory reporting becomes more structured, firms need a clear view of where the underlying information comes from, who maintains it and whether it can be retrieved reliably when needed.
If your firm is affected, now is a good time to review the technical material and prepare your questions ahead of the September session.
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