The labour-migration system of Malta entered a new phase in 2025. One very important change that was implemented in this phase is the introduction of employer thresholds when hiring third country nationals (TCNs). These thresholds are now transforming the business recruitment process and what is becoming more common is the denial of the visa, something that most people had never expected.
Each employer has now been assigned a specific number of employee they can employ with regards to TCNs. It is not a national number or a general quota , it is more like a ceiling based on the size of a particular company and its industry, workforce composition and record of compliance as evaluated by Jobsplus.
Practically, this implies that when the business has already reached its TCN quota, all new applications to hire new foreign employees, either new hires or transfer of employees to the employer will be automatically declined, irrespective of the qualifications of the applicant and the needs of the employer at that point in time.
Since the implementation, there have been numerous rejections even at the very beginning of the application process – even before the reviews of documents or qualifications. In several instances, both the employers and applicants could not realise that the threshold had been achieved.
That system is particularly problematic since:
Never submit a job opportunity to a TCN or approve a change-of-employer application without first checking with Jobsplus that the threshold status is met. Do not use previous approvals as limits vary these days. Insert threshold check into your recruitment process. As the workforce is evolving rapidly, with the slightest change in your staff, your eligibility to new TCN employees may be affected.
Be honest with applicants and tell them clearly whether the company is at its knees, as not to waste their time and money on applications.
The move to employer-specific thresholds is indicative of a larger change: under the 2025 labour-migration reforms, Malta is shifting to a comparatively open-ended TCN demand framework, to a system that is controlled and measured, in other words, one that will match foreign labour supply to actual sectoral demands and national labour market equilibrium.
At that, it is not a secret that the first to be hit will be the companies whose staff is already flooded with TCN employees or whose compliance/turnover history leaves much to be desired. In industries that are largely dependent on non-EU labour (as with hospitality, caregiving, some trades), this might be in the form of freeze hiring, staffing shortages or more competition among employers over the small TCN quotas.
This update highlights the importance of being informed and active as a recruitment agency that is well integrated in the Malta labour market. For us and our clients, this means:
This is not a bureaucratic system, this is more of a structural change which will determine the way recruitment and foreign-labour flows will work in Malta in the next few years. With the changing landscape, being ahead of the regulations will be the difference between easy hires and expensive rejections.
