The Building Industry Consultative Council has called a number of stakeholders together, asking them to come up with a list of amendments to the property declaration form introduced less than three months ago.

Schedule 8 to Legal Notice 147/2015 has to be filled in by anyone buying a property and has to be attached to the contract. It was drawn up with the Inland Revenue Department (IRD) in mind – but the BICC sees it as a golden opportunity to collate comprehensive property market statistics.

“You have all this information now being gathered but with a few changes it could be much more useful in terms of statistics,” BICC chairman Charles Buhagiar said.

The form gathers data that was until now not available to entities like the National Statistics Office and the Central Bank of Malta.

“The form is a step in the right direction and it serves the IRD’s purposes. But it is a shame that they could not wait long enough to consult with us as we would have been able to get it right first time,” Mr Buhagiar said.

“We had said some time ago that we wanted to design a better property price index… But sometimes the left hand doesn’t know what the right hand is doing!”

Apart from sales volumes, advertised prices and type of property, the BICC believes it is also important to have timely information – because this is very important for investors.

“The CBM uses advertising prices while the NSO uses contracts – but there could be a year between the time that a property is put on the market and the time the contract is signed,” he pointed out.

The Schedule 8 form gathers several aspects that were not previously available – useful for both the NSO and the CBM – such as the age of the property, its finishing and surroundings, and even its amenities. But it does not ask about the number of bedrooms and bathrooms, which could have a significant impact on the price.

It also does not give any indication of whether the property is freehold or on emphyteusis, for example.

Another lacuna for the statistical buffs is property bought on plan, where the buyer is more or less buying air space, as this is not covered by the Schedule 8 form. And these properties have a separate contract for the actual construction work - which does not have to be deposited in the registry.

It is in everyone’s interest to be able to pick up trends and monitor them

“This is perfectly legal but it is going to skew the figures substantially,” he said, suggesting something that is likely to ruffle quite a few feathers: “We are proposing that the construction contract should also be registered.”

Mr Buhagiar has asked the banks which offer mortgages to suggest ways to create one standardised form that would meet their own requirements, as it would save considerable time and energy – if needs be with an annex for additional relevant information like whether the property has a planning permit or not. He has also asked the CBM and the NSO to suggest changes and will be meeting them all after the summer to collate all the recommendations.

Apart from additional data fields, he also feels that the form needs tweaking to make it clearer, pointing out that it asks for the footprint and built area which should be better defined to make it easier for the average buyer to fill in.

The form was introduced by the IRD in order to make it easier to identify underdeclarations in property sales – without having to rely on the government architects’ random visits. The information on the form allows the IRD’s computer system to immediately flag any suspicious amounts and Mr Buhagiar said he had been told that whereas government architects were previously sent to check around 40 per cent of property purchases, that figure had gone down to around 12 per cent – a considerably more efficient use of resources, and one more likely to catch offenders.

He acknowledged that statistics were not meant to capture exceptions but trends, saying that there would always be outliers.

“As estate agents rightly point out, there is also an intangible element of demand which determines a premium over the market price. Some buyers are willing to pay well over market price,” he said.

“But it is in everyone’s interest to be able to pick up trends and monitor them.”

The BICC chairman believes that once the changes are made – which he seems quite optimistic about – a significant database could be built up over time. But he does not want to stop there: he would like to see a ‘cadastre’, a comprehensive registry common overseas, which would include details of ownership and tenure, as well as value and which would serve as a unique identification for each and every property.

“The more information we have, the easier it is for all the stakeholders at every stage of the purchase,” he said.