The published list of roles excluded from the Tourism & Hospitality Skills Pass

The official Tourism & Hospitality Skills Pass FAQ publishes a list of roles it describes as excluded from this requirement “as from the 5th January 2026” (the Skills Pass FAQ and the tourism FAQ):

• Employees working in Accounts
• Employees working in Marketing
• Employees working in HR
• Employees working in Stores
• Cleaners & Kitchen Porters

We’re quoting these role names directly from the official source, rather than rephrasing or grouping them — small wording differences can matter when you’re comparing your own job description against an official list.

The excluded roles only make sense against the rule they are excluded from. Four official pages describe that rule differently, and the summaries below preserve those differences rather than merging them:

• The two FAQs (the main Skills Pass FAQ and the tourism FAQ) say all persons who will be working within the “Tourism & hospitality Sector in Malta” need the Skills Pass, subject to exclusions illustrated by a non-exhaustive list of roles. The tourism FAQ also says that, without both certificates, you cannot apply to work in tourism and hospitality in Malta; it does not explain how that answer fits with the exclusions.
• The main Skills Pass FAQ separately says a candidate who “will be working within the Hospitality Industry or with an establishment that has an MTA licence” needs the Skills Pass, “with the exception of certain occupations”, and invites anyone who is unsure to make contact.
• The tourism homepage says the framework is governed by Subsidiary Legislation 409.22 and Legal Notice 294 of 2025, and describes the requirement for third-country nationals who plan to come to Malta to work in tourism and hospitality.
• The tourism user guidelines describe the target audience as non-EU/EEA/EFTA nationals wishing to work within the Tourism and Hospitality Industry, and say employers must check that prospective non-EU/EEA/EFTA employees hold both named certificates before applying for a Single Permit. They also say the document is informative only and that discrepancies between it and the published Legal Notice do not remove anyone’s obligation to comply with the law as published.

The FAQs speak of “all persons” working in the sector, while the homepage and user guidelines speak of third-country or non-EU/EEA/EFTA nationals; the pages do not resolve that difference. This guide reads the published list of roles as examples of the main FAQ’s “certain occupations” exception, but the answers do not say so explicitly.

A reader looking for a single threshold will not find one. The main FAQ names an MTA-licensed establishment as one circumstance, alongside working within the Hospitality Industry; it does not describe the licence as the only test. What the pages do and do not say:

• The FAQ’s “or” wording names either circumstance. The pages do not explain how borderline roles or unlisted occupational exceptions are classified, for example a role at a licensed establishment that is not in hospitality.
• “Certain occupations” is not defined. The only occupations named are the five on the list, which is described as non-exhaustive. No page defines mixed duties or how similar job titles are classified.
• Qualifications. The main FAQ answer on candidates with EU or Maltese qualifications repeats the same two circumstances and says both phases are needed. It does not explain how that answer interacts with the occupational exclusions.
• Licence status. The pages do not say how to find out whether an establishment holds an MTA licence. This guide suggests asking the prospective employer directly and including the answer, with your job title and duties, in your enquiry to Skills Pass.
• Existing permit holders are described separately. One answer describes a temporary exemption for a candidate already in Malta with a valid Maltese work permit; the answer on changing from an exempt role to a front-facing role mentions a valid permit without repeating the location condition. Both refer readers to Identità for how long the exemption lasts. That is a different question from whether a role is excluded.

For enquiries about unlisted jobs, both FAQs explicitly direct readers to info@skillspass.org.mt. The tourism homepage also lists that address; the tourism user guidelines instead list info@skillspass.com.

The official source itself frames this list as non-exhaustive — meaning it gives examples of excluded roles rather than claiming to be a complete map of every role that is, or isn’t, covered. That has two practical consequences worth sitting with:

• A role not on this list isn’t automatically included. The absence of your job title here doesn’t by itself confirm the requirement applies to you — see who needs the Skills Pass for the broader description of who the framework targets.
• The FAQs do not explain how similar titles or mixed duties are classified. This guide suggests contacting Skills Pass with your actual job title and duties when the published role names leave doubt.

In both directions, the safest assumption is that this list is a useful starting point for self-assessment — not a final verdict on your specific situation.

1. Gather your job title and your actual duties. Read the published role names against your day-to-day responsibilities as well as how your contract or job advert labels the position. The FAQs do not publish a duties-based classification test, so this is preparation for your enquiry, not a way to decide the question yourself.
2. This guide suggests asking your employer for the job details. Use the title and duties to explain your situation when contacting Skills Pass; the official FAQs do not designate the employer as the authority on whether an unlisted role is excluded.
3. Ask Skills Pass directly if you’re still unsure. The official FAQs direct enquiries about unlisted jobs to Skills Pass (the Skills Pass FAQ and the tourism FAQ). This guide suggests doing that before paying: the main Skills Pass FAQ says withdrawal refunds depend on senior-management discretion and the circumstances (the Skills Pass FAQ; see what it costs).
4. Re-check the official FAQs before relying on this list. This guide suggests checking for updates when you plan an application. The wording “as from the 5th January 2026” identifies when the listed exclusions apply; it does not say when the FAQ was last updated.