Thematic Review on the Value for Money of Products Distributed on a Cross-Border Basis

For compliance and product governance teams, this signals heightened supervisory attention on how manufacturers and distributors evidence value for money when the client relationship crosses jurisdictions. Firms should expect scrutiny of product approval processes, target market definitions, cost and charge structures, and the quality of value assessments where distribution chains involve multiple entities. The cross-border dimension adds complexity: responsibility allocation between manufacturer and distributor, availability and quality of management information from overseas intermediaries, and consistency of disclosures across markets all become supervisory focal points.

Practical implications: boards and product governance committees should be prepared to demonstrate a documented, repeatable value assessment methodology; distribution agreements should be reviewed for data-sharing and monitoring obligations; and any products showing weak value indicators should be subject to remediation plans. Governance owners should also map which products are distributed cross-border from Malta, and assess whether existing MI gives sufficient visibility of end-customer outcomes. Firms with limited oversight of foreign distributors carry elevated conduct risk and should prioritise gap assessments.

Deadlines are not specified in the notice, so compliance leadership should treat this as a prompt for proactive self-assessment and be ready to respond to information requests. Expect follow-up engagement and possible thematic feedback from the authority in due course.