MFSA Highlights Findings and Expectations on Company Disclosure Practices
On 14 July 2025, the Malta Financial Services Authority (“MFSA”) published a Dear CEO letter addressed to all chief executive officers, directors, members of management and company secretaries of public limited liability companies listed on the Official List of the Malta Stock Exchange. The letter sets out the MFSA’s findings following the conclusion of a thematic review geared towards evaluating the “quality, clarity and timeliness” of company announcements published by listed entities falling within its supervisory remit.
General observations
At the outset, the letter stresses the importance of transparency in enhancing investor confidence and safeguarding market integrity. It highlights the disclosure of accurate and timely information by issuers not only as an enabler of informed investment decisions by the investing public, but also as an effective tool for the prevention of market abuse. The MFSA identifies company announcements published on the Officially Appointed Mechanism operated by the Malta Stock Exchange as a “key method” of achieving optimal levels of transparency, and directs readers to Chapter 5 of the Capital Markets Rules (specifically CMR 5.16) which sets out minimum disclosure requirements for listed companies. In emphasising the non-exhaustive nature of the disclosure requirements listed in CMR 5.16, the MFSA seeks to encourage listed companies to go above and beyond the bare minimum expected at law; thereby building a stronger rapport with investors and contributing towards a more efficient and properly functioning local market.
In our view, while the MFSA’s focus on increased transparency and communication with one’s investment base is commendable, the culture should not suddenly morph into one of ‘announcing for announcing’s sake’, and it would therefore be undesirable if listed companies were to prioritise the frequency of their company announcements over their quality and value to the market.
Key findings
The letter identifies six key findings which we will be touching upon in brief below:
- the timely publication of information;
- the publication of financial calendars;
- the nature and frequency of company announcements;
- the accessibility of company announcements and other published information;
- the direct attachment of documentation to company announcements; and
- the publication of information of nominations of directors.
Timely publication of information and financial calendars
In assessing the timeframe between the publication of company announcements regarding the approval of financial reports and the actual approval dates of these reports (as a case study of sorts), the letter notes that the majority of issuers (circa 71%) did not bring this information to the market’s attention in a timely manner; whilst others failed to publish an announcement altogether.
In view of the foregoing, the MFSA has encouraged listed entities to adopt, as a matter of best practice, a financial calendar prior to or upon commencement of the financial year; setting fixed milestones for the approval, publication and announcement of the relevant financial reports. While conceding that circumstances throughout the year may require certain changes to be made to the dates disclosed in the financial calendar, the MFSA has maintained that any such changes can be communicated to the market by way of a company announcement for this purpose.
Nature and frequency of company announcements
The letter confirms that despite there being a consistent increase in the number of listed issuers over the past three years, there has not been a corresponding increase in the number of company announcements issued over the same period of time. This in turn indicates (in the MFSA’s view) that listed issuers ought to be strengthening their communication strategies by delivering “more consistent and timely updates to the market.” In so doing, the MFSA has provided examples of matters which would not typically be the subject of a company announcement, but which (in the name of fostering increased investor engagement) should be considered for disclosure – e.g: participation in conferences or industry events, and sustainability initiatives and progress.
Accessibility of announcements and other published information
The letter outright discourages the uploading of scanned company announcements and/or annual financial reports, owing to the fact that these are not machine-readable and would therefore impair the accessibility and readability of such information.
Direct attachment of documentation to company announcements
In view of its findings (which confirmed inter alia that 11% of issuers failed to include their 2024 interim financial statements as an attachment to the corresponding company announcement), the MFSA has taken the opportunity to remind the market of a circular previously published on 8 November 2018, wherein it urged listed entities to embed regulated information as an attachment to the corresponding company announcement/s (and to not include a hyperlink thereto in the body of the announcement).
Director nominations
In the context of equity issuers, the letter sets out the MFSA’s expectation that a company announcement regarding the nomination process be issued so as to notify shareholders that the issuer in question is accepting nominations for director positions. According to the results of the thematic review carried out, 69% of equity issuers do not currently adopt this practice.
Concluding remarks
The content of the letter, coupled with the MFSA’s emphasis on the need to “take proactive steps in reassessing and refining their market communication strategy”, seems to be ushering in a ‘new age’ of increased investor engagement (this being an area which the MFSA, and other stakeholders, have been discussing in local fora for quite some time now). That said, striking the right balance between quality and frequency of company announcements remains crucial in fostering a disclosure culture that supports regulatory expectations and market confidence, without placing undue pressure on issuers to announce purely for the sake of doing so.
