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CIR 04/26 | Construction Industry Skill Card Update

This circular serves as an update to Circular 01/2026 issued on 26th March 2026 concerning the purported requirement for periti to hold a register for a skill card.

Members will recall that on 24th March 2026 the Building and Construction Authority (BCA) was contacting periti via email indicating that they are legally required to possess a skill card to enter a construction site as from January 2027.

Circular CIR 01/2026 clarified that no such regulatory requirement exists since the regulations regarding the construction industry skills cards are still being finalised and have thus not been brought into force.

The National Building Council (NBC), composed of Kamra tal-Periti and Malta Development Association, requested an urgent meeting with the BCA to seek clarifications on the skill card scheme to ensure that there is broad consensus on the legal text and adequate time for the industry to prepare itself, particularly in view of the envisaged timeframes. The absence of published regulations was not only creating uncertainty, but making it challenging for compliant course curricula to be developed and accredited in time. Indeed, while the regulator’s intent is for the course to reach EQF Level 2, many courses claiming to be providing the necessary training for the attainment of the skill card have only achieved an EQF Level 1 accreditation.

The NBC met with the BCA on 7th May 2026 during which the above concerns were raised. In particular, the NBC emphasised that periti, whose training reaches a minimum of EQF Level 7, should not be subjected to the same regime as unskilled labourers.

The Council welcomes initiatives aimed at improving health and safety awareness and competence within the construction industry. However, the Perit profession is already regulated under a statutory warrant system, which requires advanced academic qualifications, supervised professional training, and compliance with a dedicated legal and regulatory framework.

Moroever, the new Periti Act envisages the introduction of mandatory continuous professional development governed by the Kamra tal-Periti. During the AGM of 2024, former council member Perit Dr Rebecca Dalli Gonzi had given a thorough presentation of the CPD framework the Kamra is working on, which will include health and safety and risk management as core subjects.

During the May meeting, BCA CEO Perit Roderick Bonnici agreed that periti should not be required to participate in any training courses to attain a skill card given that they are in possession of relevant academic and professional qualifications that exceed EQF Level 2, and that the draft regulations will reflect this.

The Council of the Kamra tal-Periti eagerly awaits being given a draft of the regulations when they are written to be able to also guide members of the profession on the status of non-warranted technical staff who undertake site-work.

 

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CIR 03/26 | Repeal of original Sanitary Regulations

The Kamra tal-Periti wishes to bring to the attention of all periti that the original sanitary regulations forming part of the Code of Police Laws were repealed through Legal Notice 99 of 2026.

The repeal brings to an end the legal uncertainty brought about when S.L.552.22 – Development Planning (Health and Sanitary) Regulations – were brought into force on 10th June 2016 without concurrently deleting the relative provisions in the Code of Police Laws.

The repealed sections of the Code of Police Laws through the aforementioned legal notice concerned (see end of circular – print version for full repealed legal text):

  • minimum internal clear heights [Art 97.1(d)];
  • provision of natural light and ventilation requirement, including passive vents [Art 97.1(e)];
  • street-width-to-building-height ratios [Art 97.1(l)];
  • backyard and internal yard dimensions [Art 97.1(n)(i) – (n)(iv)];
  • requirement to file for permission from the Superintendent of Public Health prior to carrying out works [Art 97.1(o)(iv)];
  • use of artificial lighting and mechanical ventilation (Art 99);
  • use of basements for habitation (Art 107 & 108);
  • formation of ventilation shafts in pavements to ventilate cellars (Art 109);
  • sanitary licensing requirements for the occupation of apartment blocks (Art 110);
  • overcrowding parameters (Art 112);
  • restriction on letting overcrowded units (Art 113);
  • exemption from observance of sanitary regulations for agricultural or husbandry facilities.

Periti are to note that this legal notice will not bring about any practical changes other than to provide legal certainty to professionals and their clients on which laws and regulations are applicable in the design of buildings.

Repealed Text from Cap 10 in the print version

 

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CIR 02/26 | PA Circular on Agricultural Land Holdings, Restoration Projects, Visual Simulations, and Minor Amendment Requests

The Kamra tal-Periti was referred a draft PA circular 2/26 on 30th April 2026 for its review and feedback. This was immediately referred to all its internal structures, in particular the Council and the Policy Committee on Heritage. The Council convened on Monday to review the detailed feedback from PC Heritage and to finalise its position on the entire circular.

This afternoon, while the secretariat was finalising the document for submission to the PA, it was noted that the PA issued the circular before receiving the Kamra’s feedback. This is deeply regretted as there are several improvements that are required to the circular as published.

While it is unusual for the Council to publish its positions on informal consultation processes, the Council felt it is appropriate to bring to the attention of members of the profession its position on the contents of the latest PA circular.

The Council shall be issuing further communications, including possible directives, on how periti are to proceed in the coming days.

 

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Photo source: Times of Malta
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CIR 01/26 | Construction Industry Skill Card

The Council refers to an email sent out by the BCA to periti on 24th March 2026 with details on how to apply and pay for a skill card. The email goes on to say that anyone not in possession of such a card will not be allowed to enter a construction site, including during the finishing stages.

After further inquiries, it emerged that the BCA is informing members of the profession that the requirement for the possession of a skill card also applies to periti.

It is pertinent to underscore that such obligation does not presently exist. There are indeed no regulations in place stipulating this requirement.

 

While the Council is in favour of upskilling labourers to ensure that they receive basic awareness training on health and safety risks until they go through further formalised training in their respective trade, periti are governed by a warrant regime based on high-level academic and professional education, and an ad-hoc law and regulator setting significantly higher benchmarks of qualifications and practice standards.

 

Representatives of the Council met with the BCA yesterday afternoon to clarify the matter. The following points were raised:

  1. The Council was not presented with any draft regulations and has thus never agreed to the imposition of such requirements on periti.
  1. Likewise, the course content has not been reviewed by the Council of the Kamra and has thus not consented to it.
  1. The Kamra tal-Periti, not the Building & Construction Authority, is the legal regulator of periti. The BCA would be stepping outside of its legal scope if it sought to regulate periti.
  1. Banning a perit from entering a construction site means that nobody can enter such a site, irrespective of whether they possess a skill card, since the Code of Police Laws requires that a perit provide general supervision on site.
  1. The Periti Act has provisions which are expected to be brought into force over the coming months that introduce mandatory continuous professional development. The CPD framework had been presented to periti during a workshop held in July 2024 and adopted in its final draft by the AGM in December 2024. Among the mandatory core subjects to be introduced is a specific course on risk management and H&S.

 

The BCA agreed to review the matter and will revert in due course. The BCA also clarified that the regulations pertaining to skill cards are still being drafted.

Meanwhile, periti are advised to await further communication from the Council on the matter.

 

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CIR 06/25 | Sanitary Regulation tolerances in Minor Amendment Applications

1. Purpose

This Circular serves to notify members of an important procedural update communicated to the Council of the Kamra tal-Periti by the Executive Chairperson of the Planning Authority. This update forms part of broader discussions on regulatory efficiency and the streamlining of policies and regulations currently being held between the Kamra tal-Periti (KTP) and the Planning Authority (PA), as well as between the National Building Council (NBC) and the PA.

 

This Circular is to be read alongside Directive DIR 05/25 on the reporting of measurements in compliance checks.

 

2. Procedural Update on Tolerances in Sanitary Regulations

The Planning Authority has adopted a new internal procedure concerning the application of the Development Planning (Health and Sanitary) Regulations (S.L. 552.22).

  • Under regulation 4, the Planning Authority may, at its discretion, permit dimensions that are lower than those stipulated, provided that compensatory measures are in place which achieve an equivalent sanitary outcome.
  • Examples of compensatory measures include the provision of a larger external aperture in lieu of a smaller aperture originally specified.
  • This internal procedure applies only in the processing of minor amendment applications – that is, applications filed by periti to amend a planning permit so as to reflect the as-built situation.
  • As part of this procedure:
    • Discrepancies of up to 2cm may be processed directly by planning officers.
    • Discrepancies greater than 2cm will be escalated and decided upon at Director grade or higher.

 

3. Important Clarifications

Periti are reminded of two key points:

  1. This tolerance procedure applies exclusively to the sanitary regulations contained within S.L. 552.22, and only within the specific context of minor amendment applications. It does not extend to other planning regulations, policies, or application types.
  2. Proposed drawings submitted with planning applications must continue to conform fully with the prescribed regulations. The discretion allowed under this internal procedure relates solely to the assessment of as-built minor amendment applications and does not in any way diminish the requirement for conformity at the original application stage.

 

Conclusion

Members are to take careful note of this update in their professional practice. The Kamra will continue to engage with the Planning Authority and the NBC to ensure that these procedures are applied consistently, transparently, and fairly across all cases, and that further progress is made in streamlining and improving the regulatory process.

 

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Photo source: PRNS
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CIR 04/25 | Commencement of Works, References for Contractors, and Design of Lift Shafts

The Council of the Kamra tal-Periti would like to bring to your attention the following updates.

 

1. Commencement of Works

Following a successful testing period, the BCA has fully transitioned to the digital site management responsibility form, which is accessible through its dedicated portal. We are informed that the initial issue of partnerships not appearing in the drop-down lists has now been conclusively resolved.

A number of partnerships have, however, requested that a dedicated login and delegation system be created for them, similar to what is available on the PA’s planning portal. At present, partners within a partnership are required to create delegations through their personal logins. While this has no bearing on liability – since liability is derived from the form itself, which is published on eApps – the Kamra has opened discussions to explore the possibility of introducing partnership logins as well.

 

2. Reference Letters for Contractors

The Council has been informed that certain officials were rejecting reference declarations submitted by periti in support of contractors’ licence applications, on the grounds that some periti had crossed out skills they had not directly witnessed the contractor executing.

These rejections are contrary to the agreement reached with BCA senior management and the Licensing Committee last year. The matter was immediately raised with the BCA CEO, and we understand that it has now been resolved.

Periti are reminded to continue following the guidance set out in Circular CIR 07/24, and to report any instances of coercion or procedural irregularities in the processing of reference letters to the Council.

 

3. Design of Lift Shafts

The MCCAA, as Malta’s competent authority on lifts, has issued a circular addressed to periti in view of a recurring pattern of poor lift shaft design, which appears to have led to an over-reliance on requests for derogations. The MCCAA reminds periti that derogations are intended only for strictly exceptional circumstances where it is genuinely impossible to meet the standard refuge space requirements.

The Council strongly advises periti to incorporate lift design standards – including lift pits, headroom, noise and vibration insulation, and structural considerations – at the earliest design stages, preferably prior to the submission of a planning application.

The full MCCAA circular addressed to periti can be found below.

The Impact of Building Designs on Lift Installations

by MCCAA

 

 

 

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CIR 01/25 | Revised Road Works Permit

Several periti have brought to the attention of the Council a new form Transport Malta (TM) has recently issued for road works permits (RWPs). Such permits are required whenever works affecting road surfaces are necessary. A common scenario for such an application is for drainage connections of new builds and service ducts.

Periti are advised that although the form needs to be filled by a perit, this does not in any way imply that it should be the perit in charge of the building project who should perform this service.

Indeed, road works can only be carried out by a restricted number of contractors authorised by TM to do so, who normally have their own in-house or sub-contracted periti. These road contractors can be found on TM’s website here.

Given that the perit of the building project was engaged solely to perform services related to the building, s/he is under no obligation to accept to provide additional services that fall outside the scope of the project or the scope of their contractual agreement with their client/s, such as filing RWP applications.

It is recommended that such RWP applications are filed by periti employed or sub-contracted by the road contractors for this purpose given the specialised nature of the task.

Regardless of who files the application form, the Council recommends anyone intending to sign such forms to consult with their PII provider to ensure that their policy covers them, particularly in view of the declarations periti are being asked to sign in the form.

It is pertinent to note that TM failed to consult the Kamra on this new form.

 

Perit André Pizzuto
President

 

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CIR 09/24 | Declarations for Y-plates (5)

Following the issuance of four circulars addressing concerns related to Y-plate operator licences, it has come to the Council’s attention that some periti may still be signing declarations that are potentially fraudulent or non-compliant with planning regulations.

The Council is actively investigating these cases to identify any instances of malpractice. Members found to have acted in bad faith or through sheer negligence may face disciplinary action, including warrant suspensions of up to one year per instance, as per recently Council-approved sentencing guideline.

We remind all periti to exercise utmost caution and diligence in their professional duties, ensuring that all necessary checks are conducted before signing declarations. It is critical to uphold the highest standards of the profession and comply fully with planning and regulatory requirements.

The Council will continue to monitor this issue closely and will provide updates as necessary. Members are advised to refer to Circular 4/24 and subsequent communications for guidance on their obligations.

 

Perit André Pizzuto
President

 

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CIR 08/24 | Declarations for Y-plates (4)

In the latest development of the ongoing saga related to the Y-plate licence renewals, the Ombudsman, through the Commissioner for the Environment and Planning (CEP), has published its Opinion on a complaint filed by an operator “that highlights significant legal anomalies and administrative irregularities surrounding the issuance and renewal of LPTS (Y-Plate) Operator’s Licences in Malta over the past year”.

The CEP made the following statements:

  1. A planning permit for a public service garage is required regardless of the number of cars accommodated in a garaging facility;
  2. There are regulatory inconsistencies in the role of the perit as envisaged in the same legal notice;
  3. The role of periti under these regulations is limited solely to new applicants without an existing operator’s licence;
  4. The Kamra tal-Periti “is correct in issuing the corresponding Circular to Architects, instructing them to ensure that the garage possesses a valid public services garage PA permit.”

 

In concluding the Final Opinion, the CEP called on Transport Malta “to convene discussions with the Planning Authority, the [Kamra tal-Periti], and the Operators to facilitate the necessary amendments to S.L.499.68”.

 

Periti are thus advised to proceed as per circular CIR 04/24 until further notice.

 

Perit André Pizzuto
President

 

Read the full Final Opinion

 

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