Circular to Credit Institutions and Financial Institutions on New Credit Intermediaries Rules in relation to Consumer Credit Agreements and on the revision of current Credit Intermediaries Rules in relation to Mortgage Credit Agreements

Firms should treat it as a distribution-chain compliance refresh: confirm intermediary licensing or registration status, strengthen onboarding and ongoing due diligence, and ensure contracts, remuneration, disclosures and oversight align with the new consumer-credit rules and revised mortgage-credit requirements. Compliance teams should map every intermediary relationship, assess contractual and operational gaps, update policies and training, and reinforce monitoring and complaint-handling escalation. Although the extract does not set out explicit deadlines, affected firms should obtain the full circular's implementation timetable and build a remediation plan before supervisory expectations crystallise.

Consumer protection and conduct risk are central, so product governance, advertising, affordability and disclosure controls across intermediary channels should be reviewed. Impact is concentrated in Malta-facing lending and mortgage distribution. Institutions using third-party brokers or intermediaries may face higher onboarding, documentation and monitoring costs, while those with robust oversight can differentiate on conduct standards.