We seem to have ‘lost’ 338,000 tourists in the first 10 months of 2016 – and nobody seems to be asking where they actually slept.

There were 1.73 million incoming tourists between January and October 2016, but only 1.39 million of them stayed in collective accommodation: hotels, guesthouses, hostels and tourist villages.

For years, we assumed that the leakage was down to a variety of factors from English-language students, to friends and relatives visiting some of the 22,000 foreigners now living here, to people staying in unlicensed accommodation.

But that leakage is now 38.7 per cent of all guest nights. Shouldn’t somebody be trying to figure out where they were and what the impact of this trend will be on the rest of the tourism sector?

For years, the Malta Hotels and Restaurants Association has been warning about the impact of people staying in alternative accommodation to hotels.

The point made at the regular updates by Deloitte has been consistent: the haemorrhage will have a short-term impact on hotels’ occupancy, and in turn on their profitability, which will have a long-term impact on their investment, which will result in a poorer product.

To make matters worse, the fight to fill rooms in a falling-occupancy scenario to cover overheads could result in room rates being dropped – a move which would take several painful years to reverse.

The warnings have been backed up by data from the regular National Statistics Office press releases but because overall tourist numbers have been rising, the impact of this growing trend has perhaps been masked.

Of course, there are various factors at play, including the fact that tourists make shorter stays than they did a decade ago. However, the bottom line is that net use of bed places is down to 66.4 per cent, the equivalent to a hotel being completely empty for four whole months of the year.

Is it due to people staying in private accommodation? To confuse the numbers even more, the NSO reported that 544,802 used private accommodation between January and October of 2016!

Paul Bugeja, the CEO of the Malta Tourism Authority had told The Business Observer some months ago that there were 2,600 licensed units on the register. And AirBnB only gives 300 options when you search for Malta but this is not necessarily all the ones available (Isn’t that an option which would only appeal to a limited cohort?). Could this account for nearly 340,000 people?

The hotel situation has been evolving: there were 39,762 bed-places in October 2006, which fell to 37,392 by October 2016. However, the Planning Authority had allowed hotels to add another storey – spreading overheads over more rooms – which had been taken up by 22 hotels in three years. There are also dozens of boutique hotels cropping up – but with a dozen rooms each, they will hardly make up for the decline, unless hotels see a reason to invest.

There may be nothing wrong with 338,000 tourists sleeping where they choose to. However, unlicensed accommodation has two implications: that it is below par, which could rapidly turn into a social media nightmare affecting the overall brand; and that the owners of this accommodation are not paying their tax and licensing dues, which is unfair on those who do – morally unfair, and also in terms of unfair competition.

Whether it is the National Statistics Office, the Malta Tourism Authority or the MHRA who undertake the research, one thing is clear: we need to know, not guess.