2026 Risk Evaluation Questionnaire (REQ) is now available on CASPAR

Submission deadlines are as follows:

• Thursday 9 April 2026: Crypto-Assets Sector, Real Estate Agents, Notaries and Gaming Operators.

• Thursday 16 April 2026: Trustees and Fiduciaries, Company Service Providers, Accountants and Auditors, Tax Advisors and Advocates.

• Thursday 23 April 2026: Credit Institutions, Financial Institutions, Investment Services and Securities Markets operators, and Insurance and Pensions entities.

Crypto-asset service providers (CASPs) will access the REQ according to their designation on CASPAR, either as VFA Service Providers or CASP, in line with their underlying licence. Entities that transitioned from a VFA licence to a MiCA licence during 2025 are required to report data covering the full 2025 reporting period.

 The following are excluded from submitting the REQ through CASPAR:

• Limited Company Service Providers that are not required to file via CASPAR, as outlined in the September 2025 Guidance Note for Limited Registered Company Service Providers.

• Financial institutions that have already submitted the REQ through the MFSA LH Portal, limited to those holding additional licences beyond those governed by the Financial Institutions Act.

Subject persons are advised that failure to submit the REQ by the applicable deadline constitutes a breach of Regulation 19 of the Prevention of Money Laundering and Funding of Terrorism Regulations (PMLFTR) and Section 5.12 of the FIAU Implementing Procedures. Administrative measures, including penalties in terms of Regulation 21, may be imposed. Subject persons that are not yet registered on CASPAR are required to complete their registration without delay, ensuring that submission deadlines are met.

BDO is equipped to assist subject persons with the compilation of the 2026 REQ and the drafting or review of the accompanying Business Risk Assessment to ensure timely and compliant submission through CASPAR.