What a Pre-Demolition Audit is
A Pre-Demolition Audit identifies and quantifies the waste a demolition or major refurbishment project will generate, before work starts. It records the building's structure and materials, estimates each waste stream by volume and mass, and sets out how each will be separated and routed to a licensed treatment or recycling facility. The intent is to move waste decisions to the planning stage, where they can still change the outcome, rather than to the skip.
When it is required
Under S.L. 549.161 — the Construction and Demolition Waste Framework Regulations, Legal Notice 311 of 2023 — a Pre-Demolition Audit must be submitted to the Planning Authority before an Executable Permit is issued, for two categories of project, mandatory from 1 January 2026:
- Major planning applications
- High-density residential developments serving sixteen or more units
Outside these two categories, a Pre-Demolition Audit is not a statutory requirement. It is nonetheless common as a planning condition on smaller developments, and worth commissioning voluntarily wherever demolition costs are a live concern — the audit gives a developer a waste and disposal cost forecast before contracts are signed, not after.
What is assessed
Building description
Year of construction, storeys and basement levels, gross floor area, structural system, roofing and façade materials, and general condition — established by site inspection and any available architectural or as-built drawings.
Waste streams and quantities
Every material stream is estimated by volume and mass and referenced against SM 810:2022 waste classification codes alongside the European Waste Catalogue: concrete and reinforced concrete rubble, masonry and blockwork, mixed rubble, timber, ferrous and non-ferrous metals, glass, plastics, and excavated soil. Where drawings are available, quantities are calculated from a measured take-off rather than a visual estimate.
Hazardous materials
Any suspected asbestos, lead paint or PCBs are flagged and recorded separately from general waste. Where a building's age or prior use warrants it, a dedicated hazardous material survey is recommended before demolition proceeds, with disposal routed exclusively through an ERA-licensed hazardous waste contractor.
Separation and treatment plan
Each waste stream is matched to an on-site separation method, an interim storage arrangement, and a named licensed treatment or recovery facility. Site segregation at the point of demolition — rather than mixed loading followed by off-site sorting — is what SM 810:2022 treats as best practice, and it is what determines whether the statutory recycling targets are realistically achievable.
Compliance against statutory targets
The audit closes with a compliance check against the recycling and re-use targets set under S.L. 549.161, including the minimum recycled content required in construction materials and in granular fill. Where a target cannot be met, the audit records the reason — site constraint, material condition, or a genuine shortage of licensed capacity.
What you need to provide to start
The list below mirrors the information the audit report itself requires under S.L. 549.161. The more of it available at the outset, the more the site survey can focus on verification rather than discovery.
- PA file number and application type — major application, or high-density residential (16+ units)
- Site address and local council or district
- Proposed development description and the reason for demolition — structural deficiency, redevelopment, age — with any supporting structural survey, condition report or PA condition
- Building particulars where known — approximate year of construction, number of storeys and basement levels, gross floor and footprint area
- Construction details — structural system, roofing material, façade and floor finishes
- Known or suspected hazardous materials, and any existing hazardous material survey
- Architectural or as-built drawings, in full or in part — their absence does not stop the audit, but it does move more of the work to the site survey
The process
- Scoping — project details reviewed and the audit quoted against the building's size, structural complexity and hazardous material risk.
- Site survey — structural system, materials and condition recorded, hazardous materials flagged, photographic record taken.
- Waste stream estimate — quantities calculated from drawings where available, referenced against SM 810:2022 and EWC codes.
- Separation and treatment plan — each stream matched to a licensed facility and a target recovery route.
- Report and submission — audit compiled, declared and issued for submission to the Planning Authority with the permit application.
Timeline depends on site access, the availability of drawings, and whether a hazardous material survey is needed before the audit can be finalised — this is confirmed at scoping rather than quoted generically.
Why the assessor matters
S.L. 549.161 requires the audit to be prepared by a warranted perit, a certified surveyor, or an environmental consultant registered with ERA as an approved Pre-Demolition Audit assessor. A submission from an unregistered party does not satisfy the regulation, regardless of its content.
GENCO is led by Ing. Nathan Gatt, ERA Pre-Demolition Audit Assessor (Assessor No. D0659) and Warranted Mechanical Engineer (Warrant No. 2140), with nine years managing Malta's largest waste treatment facility. Waste stream estimates are grounded in that operational experience rather than generic percentages, which matters directly for whether the statutory recycling targets are realistically achievable on your site.
Common questions
Is this mandatory for my project?
Only if it is a major planning application or a residential development of 16 or more units. For anything smaller, it is not a statutory requirement, though it may be requested as a planning condition or commissioned voluntarily to forecast waste handling costs.
Who is allowed to carry one out?
A warranted perit, certified surveyor, or an ERA-registered environmental consultant. Registration requires an expression of interest submitted to ERA and meeting its eligibility requirements.
What if asbestos or another hazardous material is suspected?
It is flagged and recorded separately from general waste, and a dedicated hazardous material survey is recommended before demolition proceeds. Disposal is routed exclusively through an ERA-licensed hazardous waste contractor.
Is there a fixed fee?
No. Each audit is scoped against the building's size, structural complexity and hazardous material risk, and quoted individually.