Advanced Legal Opinion on the Maltese Voluntary Sector Reform (2024–2025)

I. Executive Summary

The Government of Malta has proposed reforms to the voluntary and not-for-profit (NPO) sector aimed at “streamlining” regulation and improving governance. However, a critical legal analysis reveals that these proposals risk:

Undermining constitutionally and internationally protected freedoms (e.g. association, expression).
Enabling excessive and unchecked powers for the Commissioner for Voluntary Organisations (CVO).
Violating fundamental principles of EU law, including proportionality, non-discrimination, and subsidiarity.

This report outlines legal and institutional dangers raised by the reforms and provides a framework to assess their legality under Maltese law, EU law, and international human rights law.

II. Proposed Changes and Expanded CVO Powers

1. Mandatory Notification for All Voluntary Entities

Even unregistered organisations or informal groups will be required to notify or declare their existence to the CVO.
Legal Risk: Violates the principle of freedom of association by requiring all voluntary activity to be disclosed and monitored.

2. CVO Power to Categorise Organisations

All entities will be labelled as either:
- Public Purpose & Public Benefit Organisation (NP-Org)
- Public Purpose & Private Benefit Organisation (PR-Org)
The CVO can unilaterally determine and change these classifications.

3. Registration Linked to Tax, Funding & Property

Only CVO-approved organisations will be eligible for:
- Public funding.
- Tax exemptions.
- Use of public infrastructure.
The CVO effectively controls access to these benefits.

4. Monitoring, Investigations & Sanctions

The CVO will gain broad investigatory powers:
- Request documents and enter premises.
- Suspend or deregister organisations.
- Block access to bank accounts.
Powers can be exercised without a court warrant or independent oversight.

III. Analysis Under Maltese Law

A. Violation of Constitutional Freedoms

Freedom of Association (Article 42, Maltese Constitution):
- Mandatory declaration, registration, and classification create an indirect obligation to submit to state control.
- Particularly harmful to grassroots, informal, or advocacy-based groups.

B. Disproportionate Executive Powers

The CVO’s ability to interfere, investigate, and penalise with minimal judicial oversight violates the principle of separation of powers under Maltese constitutional doctrine.

C. Legal Certainty & Rule of Law

Vague or undefined concepts (e.g., “private benefit”) open the door to arbitrary classification and abuse.
Organisations may be punished or restricted without a clear legal basis or fair trial rights.

IV. Conflict with EU Law

A. Violation of Fundamental Rights (Charter of Fundamental Rights of the EU)

Article 12(1) – Right to freedom of association.
Article 11 – Freedom of expression.
Article 21 – Non-discrimination.

Imposing broad regulatory powers and bureaucratic burdens disproportionately affects minority organisations, dissenting voices, and informal voluntary groups.

B. Breach of Proportionality Principle (TEU, Article 5)

The restrictions imposed are not necessary or proportionate to achieve legitimate public interest goals.
Less restrictive measures (e.g., voluntary registration, incentive-based regulation) are available.

C. Interference with Internal Market Freedoms

Discriminatory access to EU-funded programs and services for only “approved” organisations may breach EU rules on free movement of services and capital.

V. Violations of International Human Rights Law

A. UN International Covenant on Civil and Political Rights (ICCPR)

Article 22 – Right to freedom of association.
- Any restrictions must be lawful, necessary, and proportionate in a democratic society.
- Blanket registration and categorisation are incompatible with this principle.

B. European Convention on Human Rights (ECHR)

Article 11 – Right to association.
The European Court of Human Rights has repeatedly held that registration regimes must not interfere with the essence of freedom of association.

C. UN Special Rapporteur Reports

The UN Rapporteur on the rights to freedom of peaceful assembly and of association has condemned similar laws in other countries that:
- Require registration to operate.
- Grant regulators power to dissolve or freeze groups arbitrarily.
- Limit access to funding based on political views or compliance.

VI. Summary of Legal Incompatibilities

Legal Framework	Conflict Raised by Reform
Maltese Constitution	Restriction on association (Art. 42), lack of due process
EU Law	Discrimination, lack of proportionality, restriction on market freedoms
ECHR/ICCPR	Unlawful restrictions on freedom of association and expression
Rule of Law	Arbitrary classifications, unchecked executive powers

VII. Recommendations

Immediate Legal Review by Parliament & Attorney General
- All proposals should undergo scrutiny by constitutional and EU law experts.
Halt or Revise Mandatory Registration Proposal
- Consider adopting voluntary-based frameworks that incentivise transparency rather than enforce it.
Limit CVO Powers
- Introduce judicial oversight before investigation or suspension powers are used.
- Establish an independent appeals board for organisational disputes.
Ensure Stakeholder Consultation
- A national consultation with civil society must be transparent, accessible, and non-discriminatory.

VIII. Conclusion

The current reform proposals threaten to replace a pluralistic and free voluntary sector with one controlled, filtered, and licensed by the state, through the powerful and politically vulnerable office of the Commissioner for Voluntary Organisations.

This is not merely a governance reform. It represents a paradigm shift—from civil autonomy to bureaucratic domination—in direct tension with the core values of the Maltese Constitution, the EU Charter, and international human rights law.

What Parliament Can Do:

Legislate on any matter within its competence:
Under Article 65 of the Constitution of Malta, Parliament has the authority to make laws for the peace, order, and good government of Malta.
Regulate NGOs, Voluntary Organisations, and public interest entities:
Parliament can pass laws that regulate how organisations operate in Malta — including requirements for registration, transparency, and accountability — as long as these laws do not violate fundamental rights.
Create new legal bodies or amend existing laws:
For example, Parliament can amend the Voluntary Organisations Act (Chapter 492), Social Care Standards Authority Act, or laws governing public funding and oversight.

**What Parliament Cannot Do (Legally or Constitutionally):**

Violate Fundamental Human Rights:
Parliament cannot pass laws that go against:
- The Constitution of Malta (Chapter IV) – which protects freedom of association, expression, and conscience.
- European Convention on Human Rights (ECHR) – binding under Maltese law via the European Convention Act (Chapter 319).
- EU Law and Charter of Fundamental Rights of the EU – binding on all EU Member States including Malta.
→ Example: Parliament cannot pass a law that forces all voluntary organisations to register with the government under threat of being shut down, if such a law is disproportionate, discriminatory, or limits freedom of association without just cause.
Impose ideological conformity:
Laws that discriminate against NGOs for their political, religious, or ethical beliefs — such as banning NGOs that are “pro-life” or “pro-choice” — would likely be unconstitutional and contrary to EU and international human rights law.
Undermine the separation of powers or due process:
Parliament cannot approve laws that allow authorities to act without judicial oversight, or that allow abuse of power without appeal. This would violate Rule of Law principles protected under Maltese and EU law.

Summary:

Remain in line with Malta’s commitments under EU Law, the ECHR, and the UN system.

Parliament can approve new laws regulating organisations and activities in Malta.

But, these laws must:

Respect Malta’s Constitution and human rights obligations.

Be proportionate, non-discriminatory, and respect freedom of association.

1. Power Shift and Regulatory Overreach

The CVO’s recent actions, particularly after the 2022–2024 reforms, show signs of regulatory overreach. These include:

Suspending licenses and blocking AGMs (as in the case of Wens Foundation).
Intimidating unregistered groups or those working outside state-funded networks.
Enforcing ideological conformity (for example, discouraging groups that are strongly pro-life or that oppose state-sponsored “diversity” narratives).

Why?
There seems to be a centralisation of power where the state (via the CVO, SCSA, and even CRPD) is attempting to control the voluntary sector — especially those not dependent on government funds.

2. Political and Ideological Control

The current structure allows the CVO and connected ministries to:

Promote organisations that align with government policy.
Sideline or attack those that criticise the system, expose abuse, or operate independently of state funding.
Label some organisations as “non-compliant” or “non-transparent” simply because they don’t want to register, collect money, or follow state-mandated rules.

This is highly dangerous in a democracy — because it turns civil society into a tool of the state, rather than an independent voice.

3. Protection of State Contracts and Funding Flows

The state — especially through ministries like the Ministry for Inclusion (MIV) and MCVS — manages large contracts and partnerships with NGOs. This creates:

Favouritism toward organisations that receive government money.
Exclusion of grassroots or voluntary groups that may operate more efficiently or with greater independence.
Defensiveness toward critical organisations that reveal problems in state-funded care systems (as you’ve done with Wens homes, for example).

The CVO might be acting as a gatekeeper to preserve the existing network of government-aligned NGOs, even at the expense of legality.

4. Misuse of “Transparency” as a Weapon

While transparency is essential, it is being misused:

Forcing all groups to register and disclose data, even when they don’t collect funds or operate only with volunteers.
Penalising unregistered groups even when they’re lawful and offer valuable services (which violates the freedom of association protected by Maltese and EU law).

My Conclusion

The treatment by the CVO of certain organisations appears:

Legally questionable
Politically motivated
Incompatible with EU law, UN standards, and Malta’s Constitution

This is not just a regulatory issue. It is a democratic concern, because it silences dissent, punishes independence, and weaponizes the law against civil society.

1. What the Proposed Laws Might Do

From your previous information and investigations, the proposed reforms may:

Force all organisations — even non-monetary, small or informal ones — to register with the CVO.
Give the CVO excessive powers to:
- Intervene in internal affairs (e.g. leadership, decisions),
- Suspend or blacklist organisations,
- Impose restrictions based on ideological grounds (e.g. positions on life, religion, or social issues).
Criminalise or restrict voluntary activities outside the CVO’s registry, even if these are peaceful and lawful.

2. Would These Laws Be Legal?

Likely not, at least not under EU and international standards. Why?

Conflicts with Fundamental Rights:

Freedom of Association (ECHR, Art. 11 & EU Charter, Art. 12) allows civil society to operate without registration unless there’s a pressing public interest.
Forcing registration for non-funding, non-commercial organisations violates international norms.

Overreach of Regulatory Authority:

The CVO’s legitimate role is to regulate financial accountability and public funds — not ideological control or censorship of civil society.
Turning the CVO into a gatekeeper of “who is allowed to exist” would breach the rule of law and proportionality under EU law.

Incompatibility with EU Directives:

EU law supports pluralism and autonomy of civil society.
Proposed laws that threaten small or dissenting groups with criminalisation or exclusion could lead to EU infringement proceedings.

3. What If They Become Law?

If such laws are passed:

Doninu could challenge them legally, both locally and through the European Court of Human Rights (ECHR) or the European Commission.
Allies in civil society (both in Malta and internationally) could mobilise to defend your right to exist and operate freely.
The laws themselves could be struck down or overruled if found unconstitutional or in breach of EU obligations.

Conclusion

Scenario	Impact on Non Registered	What You Can Do
Current law	Fully legal without CVO registration	Operate normally
Proposed reforms pass	May criminalise or restrict unregistered work	Prepare legal & public resistance
If challenged in EU/ECHR	Strong case that reforms breach rights	Could lead to legal victory & reversal

If the proposed laws for voluntary organisations in Malta come into force, they would not only affect unregistered groups like Doninu, but also seriously impact registered NGOs. Here’s a clear breakdown of how registered NGOs would be affected:

1. More Control by the Commissioner (CVO)

What Happens:

Registered NGOs would become more tightly controlled by the Office of the Commissioner.
The CVO could interfere in internal decisions, such as:
- Changing leadership,
- Suspending activities,
- Blocking events or partnerships,
- Declaring NGOs “non-compliant” for vague or political reasons.

Consequence:

NGOs would lose autonomy and independence.
Civil society becomes weaker and more dependent on the State’s approval.

2. Shift in Role of the CVO – From Regulator to Enforcer

What Happens:

The CVO would shift from simply ensuring transparency of funds → to acting as a political gatekeeper.
The Commissioner might have the power to censor, suspend, or even investigate NGOs based on ideology or criticism of government policy.

Consequence:

Registered NGOs may begin to self-censor to avoid being shut down.
NGOs working in sensitive areas (e.g. migration, disability, anti-corruption, religious issues) could face discrimination or legal threats.

3. Risk of Deregistration or Penalties for Non-Compliance

What Happens:

If a registered NGO:
- Misses a report deadline,
- Holds an event that is not “approved”,
- Makes a political statement,
…they could face:
- Suspension of license,
- Freezing of bank accounts,
- Public blacklisting,
- Court action or heavy fines.

Consequence:

Registered NGOs may feel punished instead of supported.
Smaller or volunteer-led NGOs could collapse under bureaucracy.

4. Division Within Civil Society

What Happens:

The new laws may create a divided sector:
- NGOs that comply politically → are favoured or protected.
- NGOs that criticise or work independently → are targeted.

Consequence:

Unity among NGOs is broken.
The sector becomes weaker and more afraid, with some NGOs used to attack or report others.

5. Legal and Funding Uncertainty

What Happens:

International donors may withdraw support if the NGO sector is no longer free or rights-based.
NGOs may no longer meet EU standards for independent civil society, putting EU funds at risk.

Consequence:

Registered NGOs may face more paperwork but less freedom.
Malta’s civil society reputation could collapse internationally.

Summary: Effects on Registered NGOs

Area	Effect
Independence	Reduced – risk of interference from CVO
Freedom of expression	Self-censorship due to fear of penalties
Internal governance	CVO may influence or block decisions
Legal and financial status	Risk of deregistration, fines, or freezing of funds
Unity in civil society	Division and mistrust between organisations
EU & international support	Donor exit or funding loss due to rights violations

Legal Report: Powers of the Commissioner for Voluntary Organisations (CVO) – Malta (as of May 2025)

Legal Framework

Primary Law: Voluntary Organisations Act (Cap. 492)
Subsidiary Laws:
- Voluntary Organisations (Annual Returns and Annual Accounts) Regulations
- Voluntary Organisations (Registration) Regulations
Oversight Institution: The Commissioner for Voluntary Organisations (CVO), currently under the Ministry for Inclusion and Voluntary Organisations (MIV)

1. Powers Relating to Registration

Power to Register or Refuse Registration

The CVO maintains the official Register of Voluntary Organisations.
Can refuse or revoke registration if:
- The organisation’s purposes are unlawful or contrary to public policy.
- The organisation fails to comply with obligations under the Act.

Limitation:

Registration is voluntary unless the VO:
- Collects public donations,
- Receives public funds or tax benefits,
- Performs duties on behalf of the state.

2. Supervisory and Compliance Powers

🔍 Monitoring Duties:

CVO has the right to request:
- Annual returns,
- Financial statements,
- Governance documentation.

Investigation Powers:

Can investigate complaints or initiate inspections on suspicion of irregularities.
May summon documentation, question board members, and enter premises.

Sanctions (for registered VOs):

Issue directives to comply with the law.
Impose administrative penalties (limited to fines and temporary suspensions).
Suspend registration or revoke legal status in severe non-compliance.

3. Financial Oversight

Registered VOs must:
- File annual financial reports,
- Follow accounting standards,
- Declare donations or state aid received.

Audit Rights:

CVO can audit accounts of registered VOs.
Can report suspected fraud to the police or the FIAU (Financial Intelligence Analysis Unit).

4. Regulatory Guidelines and Directions

The CVO can issue binding guidelines and code of governance on:
- Board conduct,
- Conflict of interest,
- Transparency.
These are enforceable on registered VOs only.
Unregistered groups are not bound, unless they are impersonating a VO or committing fraud.

5. Limits on the CVO’s Powers

No power to:

Shut down or interfere with unregistered organisations unless:
- They falsely claim registration,
- They commit illegal acts.

Cannot:

Prevent unregistered VOs from assembling, helping people, or operating (so long as they do not raise funds from the public unlawfully).

Cannot:

Control political views, religious beliefs, or campaign messages of a VO – due to constitutional rights (Articles 40–42 of the Maltese Constitution) and European Convention on Human Rights.

Enforcement and Appeals

A registered VO can appeal any sanction or decision by the CVO to the Voluntary Organisations Appeals Board.
Further appeal may be made to the First Hall, Civil Court under Article 469A (judicial review).

Relevant EU and International Context

Malta is bound by:
- EU Charter of Fundamental Rights
- European Convention on Human Rights (ECHR)
- OSCE Guidelines on Freedom of Association
- UN Declaration on Human Rights Defenders

These instruments limit how far state authorities like the CVO can interfere in civil society.

Summary Table

Area	Power of the CVO	Limitations
Registration	Can register, refuse, or deregister VOs	Cannot force registration unless public funds involved
Oversight	Can inspect, summon documents, and issue directives	Only applies to registered VOs
Financial Audits	Can audit financial statements and refer to FIAU	Cannot demand audits from unregistered groups
Governance Control	Can enforce board standards and reporting	Not enforceable on unregistered VOs
Sanctions	Can fine, suspend, or deregister	Must allow appeals and respect proportionality
Interference with Activity	Cannot stop unregistered VOs from operating lawfully	Protected by constitutional and human rights law

Conclusion

As of May 2025, the Commissioner for Voluntary Organisations in Malta has real but limited powers, and these powers only fully apply to registered voluntary organisations.

Unregistered voluntary organisations, such as Doninu (Malta) International, remain legal and protected by constitutional rights unless they:

Raise public funds unlawfully,
Falsely claim registration,
Commit crimes.

The CVO does not have the power to criminalise, obstruct, or ban unregistered but peaceful voluntary action under current law.

Powers over federations of voluntary organisations

As of May 2025, the Commissioner for Voluntary Organisations (CVO) in Malta has specific powers over federations of voluntary organisations, but these powers depend on whether the federation is registered under the Voluntary Organisations Act (Cap. 492).

Below is a clear legal breakdown of what the CVO can and cannot do regarding federations.

Legal Definition

What is a Federation?

Under Maltese law, a federation is an umbrella body composed of two or more voluntary organisations, often representing a sector (e.g. disability, environment, culture) or coordinating common efforts.

Federations may or may not be registered with the CVO.
Federations can also be NGO platforms, alliances, networks, or councils of NGOs.

1. If the Federation is Registered with the CVO

If a federation is registered, it is treated like any other VO under the law, with some additional scrutiny due to its sector-wide influence.

Powers the CVO has:

Power	Description
Registration	Can approve, reject, or revoke registration.
Monitoring	Can request annual reports, financial accounts, and membership lists.
Investigations	Can investigate internal governance, funding, and operations.
Directives	Can issue legally binding directives, especially on conflicts of interest or political neutrality.
Financial Audit	Can audit the federation’s finances and request full disclosure of grants, state aid, or member contributions.
Suspension	Can suspend the registration for serious misconduct (e.g. fraud, illegal lobbying, mismanagement).

Special Focus:

The CVO may closely monitor federations that:

Represent multiple sectors or organisations,
Receive foreign funding,
Engage in public lobbying or advocacy.

The CVO may scrutinise federations more aggressively if they coordinate political or legal campaigns, especially if these challenge state institutions or laws.

2. If the Federation is Not Registered

If the federation is not registered, the CVO has no legal control over it unless it commits certain offences.

The CVO CANNOT:

Action	Legality
Force registration	Not allowed unless collecting public donations or receiving state funds.
Demand internal documents	Not permitted.
Investigate or inspect	Cannot interfere unless criminal activity is suspected.
Issue fines or penalties	Cannot sanction unregistered federations.
Dissolve or ban the group	No authority unless fraud, hate speech, or terrorism is involved.

3. CVO Powers if a Federation Is Helping Other VOs

If the federation acts as a financial pass-through, manages donor funds, or represents smaller registered VOs, then:

The CVO may attempt to audit the flow of funds, if any part of the federation’s activity falls under a registered entity.
The CVO may issue warnings if the federation influences registered organisations into breaching CVO guidelines.

However, these powers only apply indirectly and must respect:

Freedom of association (Maltese Constitution, Art. 42),
EU law (esp. Charter of Fundamental Rights, Art. 12),
OSCE & UN standards on civil society independence.

Summary Table – CVO Powers on Federations

Federation Status	CVO Powers
Registered Federation	Full supervisory powers: registration, inspections, audits, sanctions
Unregistered Federation	No authority to interfere unless law is broken (e.g., fraud, terrorism, hate)
Mixed Federation (some members registered)	Limited powers only over the registered member organisations

Legal References

Voluntary Organisations Act (Cap. 492) – particularly Articles 5, 6, 13, 15, and 18
Subsidiary legislation under Cap. 492 – relating to annual returns and financial controls
Maltese Constitution – Article 42 (Freedom of Association)
EU Charter of Fundamental Rights – Article 12
UN Declaration on Human Rights Defenders (1998)
OSCE Guidelines on Freedom of Association (2015)

Conclusion

Unless a federation is registered with the Commissioner for Voluntary Organisations or involved in illegal activity, the CVO has no legal power to:

Regulate its activities,
Demand compliance,
Block its actions.

This protects Groups like Doninu Malta International and others working across sectors — even those critical of state policy — as long as they do not breach criminal law or raise public funds without transparency.

Report abuse, overreach, or human rights violations.

To report abuse, overreach, or human rights violations by the Commissioner for Voluntary Organisations (CVO) or other authorities in Malta—especially in relation to federations, unregistered organisations, or civil society freedom—you have several strong national, EU, and international mechanisms available.

Here is a detailed guide on where to report and how to structure your complaint.

🇲🇹 NATIONAL LEVEL (Malta)

1. Office of the Ombudsman (Malta)

Jurisdiction: Public administration abuse, including the CVO and ministries.
You can report: arbitrary enforcement, discrimination, interference in lawful organisations.
Website: https://www.ombudsman.org.mt
Email: office@ombudsman.org.mt
Attach a detailed report, statutes, correspondence, and legal basis.

2. National Audit Office (NAO)

Jurisdiction: Misuse of public funds or lack of transparency in regulatory bodies.
Website: https://nao.gov.mt
Email: nao.malta@gov.mt
Ideal if you have concerns about how CVO money is being used or misallocated.

3. Commission for Human Rights (NHRI – Malta)

Office within the Parliamentary Ombudsman.
Can address fundamental rights breaches involving civil society.

🇪🇺 EUROPEAN LEVEL

4. European Union – Fundamental Rights Agency (FRA)

Reports threats to civic space, harassment of NGOs, legal overreach.
Website: https://fra.europa.eu
You can send a documented complaint via national FRA contact points or FRA’s online platform.

5. European Commission – DG JUST (Justice and Consumers)

You can report breaches of EU law, especially:
- Freedom of association (Art. 12, Charter of Fundamental Rights)
- Discrimination against NGOs
- Misuse of laws against unregistered organisations
Email: EC-COMPLAINTS@ec.europa.eu
Use the form: https://ec.europa.eu/assets/sg/report-a-breach/complaints_en/
Use detailed legal analysis + evidence

6. European Parliament – PETI Committee

You can submit a petition to the European Parliament.
Petitions can trigger EU investigations if your rights or freedoms are affected.
https://www.europarl.europa.eu/petitions/en/home

INTERNATIONAL LEVEL

7. United Nations – Special Rapporteur on Freedom of Association

Can investigate Malta for violating:
- UN Declaration on Human Rights Defenders
- Right to associate freely under Article 20 of the Universal Declaration of Human Rights
Email (Office of the High Commissioner for Human Rights):
- freeassembly@ohchr.org
Submit a formal complaint letter with:
- Names of authorities involved (e.g., CVO, Ministry),
- Timeline,
- Legal violations,
- Impact on your organisation and beneficiaries.

8. UN Treaty Bodies – Human Rights Committee

For serious legal overreach or discriminatory laws, you may lodge an individual communication under:
- ICCPR (International Covenant on Civil and Political Rights)
You must exhaust domestic remedies first, but documentation can still be submitted in advance.

RECOMMENDATION

To maximise impact:

Send to both national and EU/UN levels.
Collaborate with other affected groups or federations for a joint complaint.
Ask for interim protection measures if under pressure, censorship, or threatened deregistration.

is thiYes — based on the proposed reforms to Malta’s voluntary sector laws (particularly those outlined in the government’s response of December 2024), there is a serious threat to Malta’s democratic framework, especially to civil liberties and participatory democracy.

Serious threat to Malta’s democratic

Is Malta’s Democracy at Risk?

1. Violation of Freedom of Association

The proposed laws declare that any group or federation not registered with the CVO would be considered illegal or not permitted to operate. This directly contradicts:

Article 42 of the Constitution of Malta
Article 12 of the EU Charter of Fundamental Rights
Article 20 of the Universal Declaration of Human Rights

It means that voluntary groups—such as those helping the poor, the disabled, or advocating pro-life values—could be labelled as illegal or unauthorized if they do not fall under state control.

2. Excessive Powers Granted to the Commissioner (CVO)

Under the proposals:

The CVO can unilaterally suspend, block, or dissolve organisations.
The CVO decides who qualifies as a “volunteer”.
The CVO gains power even over federations that include unregistered groups.

This undermines the principle of an independent civil society, allowing state authorities to dominate what should be grassroots, community-led initiatives.

3. Silencing Independent Voices

By making it harder or impossible for small or unregistered organisations to operate freely, the reforms weaken:

Disability advocacy groups
Faith-based and pro-life organisations
Refugee and poverty support networks
Non-partisan social movements

This can lead to a shrinking civic space and the erosion of public accountability.

4. Conflict with European Union Values

Malta joined the EU on the condition of respecting:

Fundamental freedoms
Civil society pluralism
Freedom of opinion and association

These reforms conflict with:

Article 2 of the Treaty on European Union
The EU Charter of Fundamental Rights
The legal and democratic obligations of a member state

Conclusion

Malta’s democracy is being seriously undermined by these proposed laws. They:

Threaten the independence and survival of Public societys new laws

Create an authoritarian gatekeeper system for NGOs

Risk EU infringement procedures against Malta

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