Malta Financial Services Authority Sets New Conduct Benchmark for Financial Services Decision Makers

Key Takeaways

• Clear Expectations for Leadership Conduct: The MFSA’s new General Code of Conduct clarifies what is expected from decision makers, explicitly linking governance, culture, and ethical behavior to financial stability and market confidence.
• Five Core Values Define the Framework: Integrity, informed and responsible decision-making, accountability and transparency, commitment to compliance and legal standards, and respect and fairness sit at the heart of the Code.
• Principles-Based, Not Prescriptive: The Code is designed as a proportional and risk-based framework, offering flexibility to firms while establishing a clear standard for acceptable conduct.
• Direct Supervisory Relevance: Although it does not replace existing legal obligations, adherence to the Code will be assessed during supervisory activity and may influence inspections, supervisory measures, or administrative sanctions.
• Broader and Evolving Risk Focus: The MFSA explicitly points decision makers toward ongoing responsibilities in areas such as AML, data protection, ESG, and cyber risk.

Deep Dive

The Malta Financial Services Authority has set out a clearer line on what it expects from those steering Malta’s financial institutions, publishing a new General Code of Conduct for Decision Makers in the Financial Services Industry aimed squarely at governance, culture, and leadership behavior.

Issued on January 26, 2026, the Code is less about adding another layer of rules and more about sharpening expectations at the top of organizations. The MFSA frames it as a practical guide for senior leaders and board-level decision makers, tying everyday judgment calls to the wider goals of trust, stability, and credibility in Malta’s financial system.

At its core, the Code is built around five values the regulator says should be visible in how decisions are made and defended. Integrity sits first, with an emphasis on ethical conduct and transparency. From there, the Code moves into the mechanics of leadership itself, urging informed and responsible decision-making that looks beyond short-term gains and weighs the longer-term impact on stakeholders.

Accountability and transparency feature prominently, particularly around taking ownership of decisions and ensuring financial positions are presented fairly. The MFSA also underscores the importance of sustained compliance, pointing not only to established obligations such as anti-money laundering and data protection, but also to emerging areas of risk, including ESG considerations and cyber threats. Rounding out the framework is a focus on respect and fairness, with the regulator calling for inclusive cultures where open discussion and diverse perspectives are actively encouraged.

Rather than prescribing rigid rules, the MFSA has opted for a proportional and risk-based approach. The Code does not replace existing legal or regulatory requirements, but it will carry supervisory weight. The Authority has made clear that adherence to its principles will be considered during regulatory inspections, and that material shortcomings could influence the supervisory measures or administrative sanctions imposed.

For the MFSA, the main theme is that leadership conduct is not an abstract concept but a supervisory concern. As John Sammut, Senior Technical Advisor – Internal Audit, put it, following the Code is a way for decision makers to demonstrate “a commitment to exemplary governance and responsible corporate conduct,” something he said is essential to building trust, strengthening resilience, and supporting the long-term sustainability of Malta’s financial services sector.

The Code positions tone at the top as a foundation for effective regulation, signaling that how decisions are made, not just whether rules are met, now sits firmly within the MFSA’s supervisory lens.

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