Malta audit urged withholding board pay for no meetings; revised code leaves it discretionary

Malta's National Audit Office urged ministries not to pay government-appointed board members for years in which their bodies did not meet. But the separately published July 2026 code of ethics uses discretionary language: ministries "may refrain" from paying members when a board has not convened at least once in the preceding three months. This is a documented difference in wording, not evidence that the revised code is unlawful or that a particular recipient committed misconduct.

The Auditor General's October 2026 report gathered information on 462 government-appointed bodies and 3,901 membership positions across 19 ministries, focusing its remuneration analysis principally on 2023. It found instances in which members received annual pay although their boards held no formal meetings that year. Other bodies met only once or twice but paid fixed annual remuneration rather than an hourly rate. In some cases, missing meeting counts prevented verification of payments.

The audit recommended that remuneration be backed by verifiable records of meetings and that no payments be processed if a board did not meet during the relevant year. It also recorded the Cabinet Office's verbal confirmation of the no-meeting principle. The July 2026 manual, available directly through the government's 22 July announcement, sets a three-month threshold and states that ministries may refrain from remuneration when it is missed. Whether other rules require stricter withholding in particular circumstances is not established by these documents alone.

The audit identified more than €580,000 in additional allowances and benefits paid through the end of 2023 that were not provided for in the remuneration framework, with incomplete data. Separately, it identified just over €500,000 paid during 2023 to members of boards whose rates could not be fully verified because classification records were insufficient. The two amounts refer to distinct findings and time frames and cannot be combined into a proven loss or fraud total. The report also documented underpayments to some deputy chairpersons.

The Cabinet Office said the board classification exercise was completed by March 2026 and that the revised manual introduced stronger verification, monitoring and approval provisions. The Auditor General acknowledged improvements implemented before the final report, while anticipating further follow-up.

A next reporting step is to obtain board-specific attendance and payment records, establish how ministries have used their discretion under the new code, and check whether any recoveries or corrections followed. The published audit does not identify every affected board or quantify the amount paid specifically for zero meetings.

Documents independently reviewed for this analysis: National Audit Office October 2026 report (https://nao.gov.mt/wp-content/uploads/2026/10/GovAppBodiesOct2026.pdf); Cabinet Office July 2026 manual (https://opm.gov.mt/wp-content/uploads/2026/07/Manual-for-government-appointed-board-and-committees-Cabinet-Office-2026.pdf); official Cabinet Office announcement (https://www.gov.mt/en/Government/DOI/Press%20Releases/Pages/2026/07/22/pr261236en.aspx).