Fully Online Isn’t Fully Virtual: MFHEA’s New Rules in Malta
- The Training Consultants
- Jan 20
- 5 min read
MFHEA’s latest requirements show that ‘fully online’ in Malta no longer means fully virtual — and this changes how institutions must be built, not just how they teach.
In our previous blog, we explained how MFHEA is tightening regulation around programme delivery — including timetables, languages of instruction, and online learning requirements in Malta.
This time, the focus shifts to something even more fundamental:not how programmes are delivered, but who is even allowed to apply as a fully online education provider in Malta.
One recent MFHEA communication has major implications for anyone planning to start an online education institution in Malta or apply for an MFHEA fully online licence.
When “Fully Online” Stops Being “Fully Virtual”
With Communication MFHEA 11/2025, MFHEA confirmed that new applications for licences as fully online institutions will only be accepted if specific foundational requirements are met.
In simple terms, being “fully online” no longer means being fully virtual.
Prospective providers must now demonstrate that:
They have dedicated physical premises in Malta
Core operations are based in Malta
Administrative, managerial, technical, and student support systems are located locally
The institution has a real operational presence — not just a digital platform
This applies to anyone seeking an MFHEA fully online licence in Malta. Those planning blended or hybrid learning in Malta may still apply, but only if they maintain an appropriate balance between physical and online provision.
This shift can be summed up simply:
“What makes an institution real is not its label, but the people, systems, and structures that make it work.” — The Training Consultants
What “Online Education in Malta” Now Really Means
Under the new MFHEA framework:
“Online” refers to the mode of teaching
It does not mean the institution itself can exist only in the cloud
You can teach online. But you must exist physically in Malta.
A fully online provider in Malta is now expected to be:
Physically established in Malta
Staffed locally in key institutional functions
Organised as a real education institution, not just a website with tutors
This is a major shift for anyone who imagined Malta as a base for low-cost, remote-only education models.
Practical Impact on Online Education Business Models
These new MFHEA requirements immediately change the financial and operational equation for new online education providers in Malta.
Setting up is no longer mainly about:
Building a platform
Hiring tutors
Marketing programmes internationally
It now also requires:
Physical premises in Malta
Local staffing
Operational systems for administration, quality assurance, and student support
Clear governance and management structures
In other words, online delivery now needs to be planned alongside institutional structure — not in isolation from it.
For many new projects, this simply means thinking more carefully about how delivery models, staffing, premises, and governance fit together from the start. Models that were designed as purely “virtual-first” may now need some adjustment, but with the right planning, they can still become viable and sustainable within the new framework.
Who Needs to Rethink Their Online Education Strategy in Malta?
This change particularly affects:
New applicants planning low-cost online education models
International providers wanting Malta mainly as a registration base
Entrepreneurs building platform-driven education businesses
Existing providers considering a move to fully online delivery
The key question is no longer just:
“Can we teach online?”
But:
“Can we build a real institution in Malta that happens to teach online?”
Part of a Wider MFHEA Regulatory Shift
This communication should be read alongside other recent MFHEA notices, which together show a clear change in what the Authority is now prioritising.
In January 2026, MFHEA issued Communication MFHEA 01/2026, stating that official communication during audits and accreditation must take place directly with internal institutional staff. Institutions are now expected to demonstrate real internal competence, rather than relying on external intermediaries.
Around the same time, Communication MFHEA 02/2026 limited major structural changes during institutional accreditation and reaccreditation. Institutions cannot easily change name, licence category, or ownership during this process, ensuring they are assessed as they truly operate.
When read together with MFHEA 11/2025 on fully online provision, a clear direction appears. MFHEA is no longer focusing only on what institutions promise in documentation, but on whether they are:
Structurally stable
Internally competent
Operationally coherent
Capable of functioning as real institutions in practice
The emphasis is moving away from polished paperwork alone, and toward institutional reality — how decisions are made, how systems actually work, and how responsibilities are carried out day by day.
Compliance Without Killing Efficiency
Meeting these new MFHEA requirements does not mean turning your institution into a heavy or rigid organisation. But it does mean planning with more care and intention.
Institutions now have to think about how compliance, finances, and operations work together — not as separate exercises, but as one integrated system. Decisions about staffing, systems, delivery models, governance, and support services all affect each other.
If these elements are designed in isolation, institutions often end up with structures that are costly, inefficient, or difficult to manage. When they are designed together, however, it becomes possible to meet MFHEA’s expectations while still operating in a lean, practical, and sustainable way.
The real challenge is therefore not to build “bigger” institutions, but to build institutions that are coherent, well-planned, and fit for purpose.
How The Training Consultants Can Support Online Providers in Malta
At The Training Consultants, our role has never been to replace institutions — but to build them.
Our priority has always been to help providers become self-sufficient in quality assurance and institutional management, not dependent on external support. We work alongside institutions to design systems, train internal teams, and develop real operational understanding, so that staff can confidently manage, explain, and improve their own processes.
We support providers in:
Designing governance and operational systems that make sense in practice
Building internal capacity to manage quality assurance confidently
Training teams to understand and operate their own institutional systems
Structuring online and blended delivery in line with MFHEA’s evolving framework
Our focus is simple: to help you meet every MFHEA requirement by strengthening your own institution — not by speaking in your place.
A Final Reflection
“Fully online” in Malta no longer means “fully virtual.” It now means real presence, real people, real systems, and real institutional capacity.
Those who understand this early can design their online education institutions in Malta properly from the start. Those who underestimate it may find themselves forced into costly redesigns later.
If you are planning an online or blended education institution in Malta — or reviewing your current model — this is the right moment to sense-check your structure against MFHEA’s new requirements.
A short conversation now can save months of redesign later. Contact us now for a free consultation.
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