Distributed Ledger Technology (DLT), also known as blockchain technology, has become increasingly popular in Malta over the past few years. Malta has established itself as a pioneer and leader in the blockchain and cryptocurrency space by implementing favorable regulations and legislation. This has attracted many blockchain and crypto companies to set up operations in the country. However, there has been some confusion around whether DLT and cryptocurrency activities in Malta have any age restrictions or limitations.
The short answer
There is no universal age limit set specifically for engaging in DLT activities in Malta. However, certain limitations may apply based on the specific type of activity being carried out. The Maltese government has adopted a broad regulatory framework that does not impose strict age limits but relies on existing financial services regulations.
Maltese DLT regulations do not specify age limits
Malta has been at the forefront of DLT and crypto regulation, having enacted several laws starting in 2018. Some of the key regulations include:
- Malta Digital Innovation Authority Act (MDIAA)
- Innovative Technology Arrangements and Services Act (ITASA)
- Virtual Financial Assets Act (VFAA)
None of these DLT-specific regulations contain provisions that impose age limits on activities relating to blockchain or crypto. The guidelines do not specify minimum age requirements for things like crypto trading, launching a DLT platform, or initial coin offerings (ICOs).
Therefore, the Maltese government has taken a principles-based regulatory approach that aims to balance innovation and flexibility with appropriate oversight. The focus is on regulating activities rather than imposing strict age limits.
Financial services regulations have some age requirements
While Malta’s DLT regulations do not impose age limits, certain limitations can arise from existing financial services regulations in some circumstances:
- The Investment Services Act states that the minimum age to be a director or senior manager of a financial services company is 21 years.
- The Malta Financial Services Authority (MFSA) conduct of business rulebook states that persons under 18 cannot independently open payment accounts or enter into e-money contracts.
- The Trusts and Trustees Act requires trustees to be over 18 years of age.
Therefore, Maltese persons under 18 may face restrictions when it comes to certain financial and investment activities under supervision of the MFSA. However, this does not amount to a blanket ban on all DLT or crypto activities.
Accounts and wallets have varying age requirements
The individual platform, exchange, or wallet provider may impose their own age limits for accounts or wallets. For example:
- Binance allows crypto trading and wallets for ages 18+.
- Bitpanda requires users to be over 18 for its trading platform but allows bitcoin wallets for ages 14+.
- Coinbase imposes an age requirement of 18+ for all activities.
Therefore, minors may be restricted from accessing some popular centralized crypto trading and wallet platforms. However, they could potentially still engage in decentralized DLT activities subject to parental consent.
Gambling platforms have an 18+ age limit
Online gambling platforms, including crypto-based gambling, have a minimum age requirement of 18 in Malta. This is mandated by the country’s gaming regulations.
Therefore, persons under 18 are prohibited from activities like:
- Online betting or gambling with cryptocurrencies
- Visiting or participating in crypto casinos
- Engaging in crypto gambling games or tokens
This applies even when using decentralized gambling platforms due to the territorial applicability of Maltese gaming laws.
Age limits may increase over time
As the DLT and crypto ecosystem matures, Malta may consider imposing more stringent age verification mechanisms or minimum age requirements. The EU is also planning regulations to increase supervision of crypto assets which could include age restrictions.
For now, the Maltese approach does not impose rigid age limits but gives discretion based on specific circumstances. However, the regulatory framework is evolving so any age requirements are subject to change.
Parental consent provides some flexibility
Currently, the lack of strict age limits in Maltese DLT regulations allows some flexibility for minors provided they have explicit parental consent. For example, with parental consent, those under 18 could potentially:
- Open custodial crypto wallets
- Buy, sell, or trade cryptocurrencies
- Launch innovative DLT platforms or projects
- Participate in ICOs or token sales
However, limitations around financial services and gambling would still apply even with parental approval. As regulations develop, parental consent exceptions may be formalized or restricted.
Verification challenges remain
Despite the absence of defined DLT age limits, real-world verification remains challenging. Crypto and DLT activities are often pseudonymous, so verifying actual vs stated age can be difficult. For example:
- Centralized platforms rely on customer self-verification which can be falsified
- Minors could potentially access decentralized apps and protocols without age checks
- New regulations may increase pressure for stricter verified identity and age checks
Therefore, minors could find ways around implied age restrictions, but this regulatory gray area may not last as oversight increases.
Non-financial activities have fewer limits
Maltese residents under 18 face fewer limitations when participating in non-financial DLT activities like:
- Running a validator node
- Mining cryptocurrencies
- Contributing to blockchain protocols or apps
- Launching a non-financial DLT platform or startup
These decentralized and non-financial use cases are not covered explicitly by existing regulations. However, some network-level restrictions may still apply, and increased regulatory scrutiny could lead to new limitations.
Employment and internships are possible
With parental consent, minors can potentially gain DLT work experience through:
- Internships with crypto companies
- Freelance blockchain development roles
- Employment at DLT startups
This can be a valuable way for teenage DLT enthusiasts to deepen their practical expertise and contribute to the ecosystem.
Education and training options available
There are many educational and training opportunities related to DLT available to minors in Malta, including:
- University DLT courses and degree programs
- Vocational certifications in crypto-economics or blockchain development
- Private DLT and crypto educational courses
- Conferences, seminars, workshops
These can help students and teenagers prepare for future careers in blockchain technology before reaching adulthood.
Conclusions
In summary:
- There is currently no universal age limit for engaging in DLT activities in Malta
- Financial services regulations impose some limits around investment activities and accounts for minors
- Individual crypto platforms and wallets may have imposed age limits
- Gambling activities have a 18+ age requirement
- Parental consent provides some flexibility for minors to participate
- Regulations are evolving so age limits may increase over time
- Educational and non-financial DLT activities remain open to minors
Malta takes a principles-based approach without being overly prescriptive on age limits for DLT participation. However, as the regulatory environment matures, there may be pressure to impose more formal age restrictions – especially for investment activities and platforms. This could reduce the flexibility currently available to tech-savvy teenagers. But for now, Malta provides plenty of opportunities for minors to engage with DLT – with a few limitations.