Risk Evaluation Questionnaire

2026 Risk Evaluation Questionnaire (REQ)

The FIAU would like to inform subject persons of the upcoming REQ submission deadlines for 2026. A copy of the REQ templates will be available for download in the first week of February on this portal.
Only minor amendments have been made to the REQ template compared to last year.

Subject persons are reminded that the REQ 2026 can only be submitted through the CASPAR portal.

REQ submission Deadlines:

Thursday 9th April 2026

Virtual Financial Assets Service Providers
Real Estate Agents
Notaries
Gaming Operators

Thursday 16th April 2026

Trustees and Fiduciaries
Company Service Providers
Accountants and Auditors
Tax Advisors
Advocates

Thursday 23rd April 2026

Credit institutions
Financial Institutions*
Investments Services and Securities Markets
Insurance and Pensions

*Excluding those financial institutions that are required to submit the REQ through the LH Portal. This applies only to financial institutions that also hold other licences beyond those covered under the Financial Institutions Act.

Subject persons operating in categories falling on different deadlines should follow the last deadline.

Failure to submit the REQ within the respective deadline contravenes Regulation 19 of the Prevention of Money Laundering and Funding of Terrorism Regulations (PMLFTR) and Section 5.12 of the Implementing Procedures. Consequently, subject persons found in breach may be liable to the imposition of an administrative measure, including the imposition of an administrative penalty in terms of Regulation 21 of the PMLFTR.

The FIAU reminds subject persons who are not yet registered on the CASPAR portal, that they are obliged to do so without further delay. Guidance on the registration process can be viewed by accessing the Below documents

CASPAR user guide Two-Factor Authenticator

Once the registration is accepted, subject persons can view and complete the REQ 2025.

Subject Person Profile

Subject Persons are reminded of their obligation to ensure that the ‘Subject Person Profile’ module on CASPAR is kept up-to-date with the Subject Person’s information, including:

  • Information on the subject person’s ownership and its structure;
  • Information on the group that the subject person makes part of (if applicable);
  • Details of shareholders, beneficial owners and directors of the subject person;
  • Information on the turnover and net asset values;
  • Information on the target markets;
  • Details of the subject person’s external auditor (if applicable); and
  • A copy of the subject person’s business risk assessment.

Communication

Subject persons are reminded that any queries in relation to CASPAR and the submission of the REQ 2025 should be sent via email [email protected]

If the subject person did not engage in any ‘relevant activity’ or ‘relevant financial business’ as defined by Regulation 2(1) of the Prevention of Money Laundering and Funding of Terrorism Regulations during the year under review, it is expected to reach out to the FIAU, prior to the REQ deadline, via email on [email protected] wherein it must provide an explanation of the situation in order to request an exemption from filing the REQ. If accepted by the FIAU, the subject person will not be required to complete the REQ.

For more information, please visit the FAQs on https://fiaumalta.org/app/uploads/2023/12/FAQ-Risk-Evaluation-Questionnaire-v2.pdf

 

2025 Risk Evaluation Questionnaire (REQ)

A copy of the revised 2025 REQ per sector is available by clicking the relevant sector below. This will allow subject persons to start collecting and collating the necessary information to be able to complete the REQ on CASPAR.

Financial Sector

*Excluding those FIs that submitted the REQ through the LH Portal, therefore, only FIs who also hold licences under the provision of the Investments Services Act, the Insurance Business Act or the Insurance Distribution Act.

Designated Non Financial Business and Professions (DNFBPs)

Gaming Sector

Virtual Financial Assets Sector

REQ Submission Process and Deadline for Financial Institutions (FIs)

 

The FIAU informs financial institutions licensed under the Financial Institutions Act that the REQ must be submitted through the MFSA’s License Holder (LH) Portal at https://lhportal.mfsa.mt , as in previous years. When saving the file for upload, subject persons should include their unique LH code (allocated by MFSA) in the file name.

 

The submission deadline is 31 January 2026, in line with MFSA reporting requirements. An Excel file containing specimen REQ questions is available for preview and download below. MLROs and designated employees are encouraged to review this promptly to ensure timely and accurate submissions. Only minor amendments have been made to the REQ template compared to last year.

The Subject Person Profile and Business Risk Assessment (BRA) submissions remain unchanged and must be uploaded via CASPAR. Financial institutions will be prompted to complete the applicable payment for the REQ submission through CASPAR, with instructions communicated via official notification when due. The BRA can be submitted at any point during the year once updated, so there is no need to submit it on 31 January if updated later.

For any queries about the REQ, kindly contact [email protected]

FI REQ Specimen

Guidance to subject persons in relation to the REQ can be accessed below

FAQ – Risk Evaluation Questionnaire

Subject Persons Profile

Subject Persons are reminded of their obligation to ensure that the ‘Subject Person Profile’ module on CASPAR is kept up-to-date with the Subject Person’s information, including:

This information includes:

  • Information on the subject person’s ownership and its structure;
  • Information on the group that the subject person makes part of (if applicable);
  • Details of shareholders, beneficial owners and directors of the subject person;
  • Information on the turnover and net asset values;
  • Information on the target markets;
  • Details of the subject person’s external auditor (if applicable); and
  • A copy of the subject person’s business risk assessment.

Communication

Subject persons are reminded that any queries in relation to CASPAR and the submission of the REQ should be sent via email [email protected].

risk

If the subject person did not engage in any ‘relevant activity’ or ‘relevant financial business’ as defined by Regulation 2(1) of the Prevention of Money Laundering and Funding of Terrorism Regulations during the year under review, it is expected to reach out to the FIAU, prior to the REQ deadline, via email on [email protected] wherein it must provide an explanation of the situation in order to request an exemption from filing the REQ. If accepted by the FIAU, the subject person will not be required to complete the REQ.

CASPAR

The FIAU’s Compliance and Supervision Platform for Assessing Risk (CASPAR) is an efficient, user-friendly and automated system; implemented to support the Supervision Section in the monitoring of Subject Persons, through the collection of relevant data and information.

Notifications of the appointment and/or replacement of the MLRO and/or Designated Employee are to be made through CASPAR. The annual Risk Evaluation Questionnaire (REQ) is also required to be submitted by Subject Persons through CASPAR within the deadlines announced by the FIAU. It is highly recommended to read the User Guide carefully before attempting registrations and/or compilation of the REQ. This User Guide also features a list of Frequently Asked Questions (FAQ’s) compiled to facilitate either process.

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