On 11 November 2025, the Republic of Maldives enacted its first comprehensive Trademark Act (Law No. 19/2025), replacing decades of reliance on informal cautionary notice publications with a modern, examination-based registration regime — set to take effect on 11 November 2026.

Historic Legislative Development

The Trademark Act establishes the country's first comprehensive statutory framework for trademark protection, featuring examination procedures, opposition mechanisms, well-known mark protection, and civil and criminal enforcement remedies. The Act is scheduled to come into force twelve months after enactment, providing a transition period for stakeholders to prepare and for the government to establish the necessary administrative infrastructure.

Institutional Framework: The Maldives IP Office Act 2025

The Trademark Act will operate alongside the Maldives Intellectual Property Office Act 2025 (Law No. 12/2025), which establishes a dedicated IP office responsible for examining applications, maintaining the register, conducting oppositions, and administering enforcement. The IP Office Act takes effect 1 January 2026 — a ten-month head start before the Trademark Act's substantive provisions activate, intended to let administrative capacity and systems be in place before applications can be filed.

Regulatory Timeline

Implementing regulations — covering application procedures, fee schedules, examination standards, and recordal procedures — must be published no later than 11 May 2027, eighteen months after enactment. Until published, several operational details remain unclear, and practitioners should monitor regulatory developments closely.

Key Features of the Act

The Critical Open Question: Status of Existing Cautionary Notices

For decades, trademark protection in the Maldives has relied on cautionary notices published in newspapers and official gazettes. The Act contains no express transitional provisions governing how existing cautionary-notice holders are treated under the new system — creating genuine legal uncertainty as to whether publication history confers any statutory priority or seniority.

Notwithstanding the absence of statutory priority, existing cautionary notices are expected to retain real evidential value: as proof of prior use and acquired distinctiveness, as support in opposition proceedings against conflicting applications, as grounds for well-known mark claims, and as a defence to non-use cancellation. Given this uncertainty, we strongly recommend that trademark owners maintain their existing cautionary notice publications until the new system is fully operational and formal registration has been secured.

A Reported Transition Period — Still Unconfirmed in Law

It has been reported in IP circles that the government intends a twelve-month transition window (11 November 2026 to 11 November 2027) during which cautionary-notice holders may secure priority registration before the general public can apply for the same marks. However, absent express statutory language, the legal mechanism for this remains unclear — including which notices would qualify, what evidence would be required, and how competing cautionary-notice claims to the same mark would be resolved. Rights holders should watch the implementing regulations (due by 11 May 2027) closely for clarification.

Strategic Recommendations for Rights Holders

  1. Audit existing trademark portfolios to identify all marks currently protected via cautionary notice, and assess priority for formal registration under the new Act.
  2. Compile and organise documentation evidencing prior use — dated samples of use, sales data, market recognition evidence, and cautionary notice publication records.
  3. Monitor the implementing regulations for procedural requirements, fees, and any transitional provisions.
  4. Maintain existing cautionary notice publications throughout the transition period.
  5. Prepare to file promptly once the registration system opens, particularly if a transitional priority period materialises for cautionary-notice holders.

International Alignment

The Act positions the Maldives for fuller participation in the international IP system. The country has not yet acceded to the Paris Convention, the Madrid Protocol, or the Nice Agreement, but establishing a modern registration system aligned with international standards is an essential precondition for such accessions — a trajectory the Act's convention-priority and well-known-mark provisions clearly signal.

The absence of express transitional provisions for cautionary notices is the single biggest source of uncertainty in this reform. Until implementing regulations clarify the position, maintaining existing cautionary notices and building a documented evidence trail of use remains the safest course for any brand owner with Maldivian interests.