Guide
The Malta VFA licence: what happened to it, and to its holders
Updated
Malta built the first bespoke crypto regime in Europe in 2018 and then dismantled it on schedule. If you are reading about a VFA licence, you are reading about a framework that no longer exists.
The framework Malta had
The Virtual Financial Assets Act, Chapter 590 of the Laws of Malta, came into force on 1 November 2018. It regulated initial VFA offerings and VFA services, required a whitepaper registered with the MFSA, and ran an unusual gatekeeper model in which applications were submitted through a registered VFA agent. That agent requirement was removed by Act XIV of 2024 before the framework itself was wound up.
How it was wound up, date by date
- 1 August 2024
- No further VFA licence applications or whitepaper registration requests could be submitted to, or accepted by, the MFSA (Cap. 590, articles 64(2) and 65(2)).
- 30 June 2024
- Any registered whitepaper relating to an e-money token was automatically deregistered (article 65(3)).
- 30 December 2024
- Any registered whitepaper for a virtual financial asset other than an e-money token or asset-referenced token was automatically deregistered, and articles 3 to 13 of the VFA Act ceased to have effect (article 65(4) and (5)).
- 1 July 2026
- The end of the transitional period. Persons licensed under the VFA Act on 30 December 2024 could continue providing VFA services until that date, or until a MiCA authorisation was granted or refused, whichever came first (article 66(1)).
- 2 July 2026
- Every remaining VFA licence was automatically cancelled (article 66(2)).
- 3 July 2026
- The Virtual Financial Assets Act was repealed (Markets in Crypto-Assets Act, Cap. 647, Part XII). legislation.mt now records Chapter 590 as not in force, repealed by Act XXXVI of 2024.
What VFA licence holders were offered
The MFSA split the population in two. Its circular of 10 December 2024 on the authorisation process for MiCA applicants defines Category A entities as those licensed under the VFA framework before 30 December 2024, and Category B as those still applying and not yet licensed on that date.
- Category A could use the grandfathering period and, or, apply through the simplified procedure. Their file was: a board resolution confirming the intention to apply for MiCA authorisation and to surrender the VFA services licence once authorised; payment of the reduced application fee under regulation 6(2) of the fee regulations; and either confirmation that documents from the MFSA's 2024 MiCA thematic exercise were final, or submission of the missing material against the thematic questionnaire.
- Category B could not use the simplified procedure at all. They had to start a fresh application under the MiCA Act and go through the full authorisation process, beginning with a signed statement of intent.
The reduced fees, and the fact that they are gone
Regulation 6(2) of the Markets in Crypto-Assets Act (Fees) Regulations halved the application fee for VFA service providers applying between 30 December 2024 and 1 July 2026: EUR 5,000 for class 1, EUR 10,000 for class 2 and EUR 12,500 for class 3, against EUR 10,000, EUR 20,000 and EUR 25,000 for everyone else. That window is closed. An application made today pays the regulation 6(1) rate whatever the applicant used to hold.
If a provider still advertises a "Malta VFA licence" as a live permission, check the MFSA's register. The Act creating it has been repealed and the licences it granted were cancelled.