Taken together, the data shows that since 2006, Malta has lost at least 1.94 square kilometres of green land. The largest shift appears to be after 2012, which accounts for 90% of the land lost in the period under review.

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According to the European Environment Agency, “the continuous loss of ecosystem functions renders [Europe] increasingly vulnerable when it comes to food self‑sufficiency and natural disasters”, and that going forward, governments should protect the most productive land from development.

A patchwork of strategies and plans governs development that converts natural or agricultural land into built-up areas. Sustainability goals exist in the Development Planning Act and local plans, but regulation, starting from the PN government’s rationalisation exercise in 2006, has allowed limited green spaces on the islands to be developed.

The government, in turn, is one of the largest developers of green land into grey space, contributing at least 112,467 m2 through prominent projects like the Hal Far expansion, Central Link, Addolorata cemetery, and airport runway expansion.

The Development Planning Act

The Development Planning Act includes a non-enforceable declaration that “It shall be the duty of the Government to enhance the quality of life for the benefit of the present and future generations” and “to consider public values, costs, benefits, risks and uncertainties involved when taking any decisions”.

The Act states that “In the pursuance of its functions under this Act, the [Planning] Authority shall, as far as possible, make reference to European Union best practices and standards”. The EU has set a goal of no net land take by 2050, which means no further increase in the share of land converted from natural to artificial surfaces. This means new land can still be built up, but it would need to be compensated by recultivating other built-up land.

The same law also stipulates that “no development shall be carried out except with development permission”. Development is defined as “building, engineering, quarrying, mining or other operations for the construction, demolition or alterations” or the making of any material change in use of land or building and sea, with limited exceptions such as maintenance. 

But the Act also opens a pathway to regularise development carried out without permission. A parliamentary question asked in 2023 revealed that over 2,000 illegally built structures were sanctioned between 2013 and then.

Moviment Graffiti and the local council challenged the Qala development mentioned earlier partly on the grounds of its negative impact on agricultural land. The court accepted the challengers’ arguments that agricultural use should be retained, and called the earlier tribunal’s reasoning that other uses, such as recreational pools, are permissible because they are not excluded by policy, “absurd”. For this reason alone, the court upheld the appeal, finding that the development was not permissible and the encroachment into agricultural land should not have been allowed.

A fresh application to sanction two pools in the same development is pending. 

In response to Amphora Media’s questions, the developers’ spokesperson said that “the land in question was already scheduled for development. The choice was therefore not between development and leaving the site in its natural state, but between one comprehensive, coordinated development and the possibility of approximately 40 individual plots being developed separately by different owners over time. We are very proud of the resulting development.”

The spokesperson added that “the relevant fines are being contested and we are currently pursuing the applicable sanctioning process” and that the developers “do not accept the characterisation that [the pools] were simply “illegally developed”, particularly while […] comparable pool developments on ODZ land have been permitted or sanctioned elsewhere in Malta and Gozo.”

Strategies, policies and plans

The entire territory of Malta is to be developed according to a Spatial Strategy. Local plans are adopted to manage development where that strategy is not enough.

In the early 90s through 2006, the government adopted policies and plans to regulate development in rural settlements outside the development zone (ODZ). The Rural Policy and Design Guidance, adopted in 2014, explicitly allowed expansion of buildings and introduction of enterprises in rural areas. The policy conflicted with adopted local plans, and in 2024, the government began revising the plans to avoid such conflicts.

The guiding principles in plans and strategies are written to safeguard localities from encroachment by construction. For example, the 2006 Gozo and Comino Local Plan stipulates that the overall strategy on these two islands encourages development that “improves the quality of life and the environment”, “is compatible with surrounding activities”, and “does not constitute over-development”.

“The extensive rural areas in Gozo and Comino require protection measures, and this is achieved by restraining further urban expansion, by protecting areas of conservation value and by designating strategic open space gaps between existing settlements,” the plan continues. 

As developments such as structures in Qala, which build over such open space gaps, suggest, expansions of built-up areas are approved anyway. 

Adopted in 2015, the Strategic Plan for the Environment and Development (SPED) allows “social and community facilities” for education, health, and care for elderly people, among others, to be located in rural areas where “no feasible alternatives exist” in urban areas.

The Planning Reforms 

In 2020, the government changed the fuel stations policy, capping their total number and effectively banning new fuel stations on agricultural land. Extensions of fuel stations outside development zones are no longer permitted.

Earlier in July, the government announced a planning reform by which, when a development permit is subject to appeal, works must be suspended for the appeal’s duration rather than being allowed to continue or even be completed while the appeal is pending. The reform also introduces time limits for considering appeals: a tribunal must convene within 30 days of works being suspended and take no more than six months to reach a decision. Critics have pointed out loopholes in the reform.

Unveiling the reform, planning minister Jonathan Attard said it was proof that “the political commitments we have made to the people are being turned into concrete action, by placing quality of life, public trust and the rule of law at the heart of the planning system.”

The pattern is not one of missing rules, but of rules with built-in exits. The Development Planning Act’s duty to protect quality of life is declaratory and cannot be enforced against the Authority. SPED permits community facilities on rural land where no urban alternative is judged feasible. The Rural Policy and Design Guidance allowed rural buildings to expand in conflict with local plans, until the plans were revised to match. And where building happens without permission, the Act provides a route to regularise it: more than 2,000 illegal structures were sanctioned between 2013 and 2023.Of the 1.94 square kilometres lost since 2006, 90% went after 2012. 

“The countryside and coast remain two of the most important natural resources to conserve and protect from inappropriate development,” the 2006 Gozo and Comino Local Plan reads. It did not protect the agricultural land.

Agriculture is an environmental double-edged sword. On one hand, it is Europe’s largest contributor to biodiversity loss. On the other, half of all species in the EU rely on agricultural habitats. 

According to the European Environment Agency, conversion of natural or semi-natural land (it includes cropland) into artificial surfaces “reduces ecosystem resilience by fragmenting landscapes, decreasing carbon storage and biodiversity capacity, increasing flood risk through higher surface run-off, and intensifying heatwave impacts in urban areas” while also decreasing quality of life.

A new investigation by Amphora Media, guided by Arena for Journalism in Europe and supported by The Malta Environment Foundation, reveals that Malta lost nearly 830,000 square metres to construction between 2018 and 2023. Since 2006, Malta has lost at least 1.94 square kilometres of green land.

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A deep learning image recognition model compared satellite images over time and flagged land that appeared developed from above, with journalists manually removing incorrect data.

When reviewing satellite imagery, Amphora Media’s team found land in rural areas that was used for parking cars, boats, and other scrap material, unable to serve its ecological function.

Between 2012 and 2018, around 920,000 square metres were taken up, according to the European Environment Agency’s estimate. 

Figures show that in nearly 95% of the take-up, farmland rather than natural area was affected. Around 26% of the Maltese islands’ area is covered by artificial surfaces, and almost 15% is built up as of 2022. 

“We cannot continue to sacrifice agricultural land for short-term economic gains,” BirdLife Malta, an environmental NGO, said in response to a new agricultural policy document earlier this year.

Agricultural land in the city to be built over

Concerns about the loss of agricultural land boiled over again in a discussion about an application to develop a plot in Swatar, a highly urbanised area. 

“Once again, the Planning Authority has chosen to side with developers instead of protecting the environment and the quality of life of residents,” the Momentum party said in a press release, reacting to the approval of the planning application.

“Beyond its agricultural value, this space plays an important role in the daily lives of residents. It offers a sense of openness in a dense urban environment, supporting both physical and mental well-being. It also serves a critical environmental function by absorbing rainwater runoff, helping to reduce flooding risks in surrounding areas, particularly in Msida,” Flimkien għal Ambjent Aħjar, an environmental NGO, said

Agricultural sector in decline

Declining farmland goes hand in hand with Malta’s dwindling agricultural sector.

Between 2018 and 2023, Malta produced nearly 8% less vegetables and 12.3% less fruit (by weight). Between the two last agricultural censuses, 2010 and 2020, Malta lost nearly one in six agricultural holdings and over 6% of utilised agricultural land.

When development competes with agricultural land, its prices only rise. According to the latest agricultural census, Maltese farmers have 10,731 hectares of farmland, and about half of it is rented from the government. Land purchase prices in Malta are by far the highest in the EU.

“In Malta, one of the smallest countries in the world, land comes at a premium, and access to land is very limited. So if you have a new farmer, it’s almost impossible to enter the sector because they don’t have access to land and water,” Malcolm Borg, who leads Ghaqda Bdiewa Attivi, told Amphora Media in a previous investigation.

Despite farmers asking for help to afford land, Amphora Media’s earlier investigation has shown that funds earmarked by the EU to support farmers are routinely directed to road-building in Malta.

Cover image by: Joanna Demarco

Among the 20 largest pieces of land to be developed, the government is responsible for developing at least 112,466 m2 of land, roughly 13% of the total developed from 2018 onwards.

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This analysis did not examine the circumstances of planning application approvals and focuses only on land-use change. There is no implication of wrongdoing.

These developments chip away at cropland and natural areas, making Malta one of the top countries in Europe for land loss to development.

Amphora Media has examined some of the largest land take-up projects. The research was based on analysis of satellite imagery [link to methodology]. 

No. 1 – Ħal-Far Industrial Estate – 32,948 m2

The plot is located within the Ħal Far Industrial Estate, managed by INDIS Malta, and has served as an industrial zone for decades. Back in 2018, this particular piece was an undeveloped field, and the converted area makes it the largest land take-up during the analysed period.

In 2022, Minister Silvio Schembri announced the relocation of Elepac Ltd’s factory to Hal Far. In 2024, the company applied to convert part of its factory to a waste management operation. According to reports, the land footprint was smaller than at the factory’s previous location.

In response to Amphora Media’s questions, INDIS Malta said that “INDIS Malta has never converted Outside Development Zones (ODZ) for industrial purposes. On the contrary, it has actively released thousands of square metres of land previously designated as industrial back to the Lands Authority so that they can be reverted to ODZ.”

No. 2 – Concert Grounds in Ta’ Qali –  24,131 m2

Concert Grounds in Ta’ Qali was the second-largest expansion of built-up area, although satellite images show paths and structures in the area as of 2018. A permit to build concert facilities was granted in 2021 and included landscaping.

The Parks in Malta website describes the area used for concerts in Ta’ Qali as “previously derelict” and since transformed into “soft and hard landscaped spaces”. For prominent concerts, the location is indicated as Ta’ Qali National Park.

Instead, as reported in the media, the government has controversially paved gravel over a large picnic area within the adjacent national park, raising concerns about its impact on the soil, the material’s suitability, and its cost.

No. 3 – Addolorata Cemetery – 23,848 m2

The expansion of the government-owned Addolorata cemetery was the third-largest land take-up identified in the data. In 2019, Chris Fearne, then Minister of Health, announced the cemetery extension, adding 2,880 new graves.

No. 4 – Mqabba Quarry – 20,692 m2

The Mqabba quarry is the fourth-largest development. The plot, identified on Google Maps as Sier and Sons, is licensed for handling inert and excavation waste, among other activities. 

Quarries are included in the data as they are disturbed land that no longer supports ecosystems, and quarrying, alongside mining, is mentioned as development in the Development Planning Act.

No 5: Central Link Project 19,136.1 m² (combined two sites 6,586.46 m² + 12,549.64 m²)

Road expansion in Attard for the Central Link project, across two areas, was one of the largest intakes. 

Environmental groups had challenged the project in court and lost. Meanwhile, Infrastructure Malta insisted that the project would “halve travel times” and bring “better quality of life for thousands of residents”.

No. 6 – Shoreline Mall – 19,067 m2

The Shoreline Mall has occupied what used to be coastal land. Complete with trampolines and wall climbing, and home to a Starbucks and numerous global clothing brands, the mall is ultimately owned by five businessmen.

No. 7 – Quarry in Dingli 18,116 m2

Satellite image shows how fields were replaced with a busy developed site with stripped topsoil. 

No. 8 –  Estate – 17,612 m2

The estate, home to General Maintenance Ltd, an engineering company, and MaritimeMt, a training academy for maritime professionals, was once a field.

No. 9 – Gozo Plot –  16,425 m2

[Updated] The Gozo plot, which used to be covered with fields, was indicated as hosting Malta Rescue Corps, an emergency response organisation. When contacted, the organisation sent the following correction: “We would like to clarify that the location indicated […] is incorrect. It had been marked wrongly, and this was updated [On Saturday 12 September].”

No. 10 – Quarry 15,147 m2

Land covered in fields has seen apparent quarry expansion. ERA lists six quarries in the area.

No. 11 – AX Centre in Mosta –  14,719 m2

A field surrounded by development has become the AX Business Centre in Mosta. AX Group calls this development “sustainable” and “eco-conscious”.

No 12: Antoine Camilleri block in Naxxar – 14,552 m2

A large area of rural land in Naxxar is being turned into a 6-floor development with underlying garages. Developed by Antoine Camilleri with Onyx.

The development entered the news earlier this year after the threat of a major collapse saw residents evacuated.

No. 13: Qala ODZ-Pools – 13,751 m2

The Hal Wardija resort apartments complex in Qala has replaced fields that broke up a heavily developed landscape in Gozo. The area is marketed to tourists as “quiet”.

This development consisted of separate applications to build garages and apartments. Pools were built illegally and then sanctioned, but a court later revoked that decision. Excel Investments Ltd filed the applications; it is co-owned by Daniel Refalo, Joseph Portelli, and Mark and Joseph Agius, and the fines for the illegal pools remain pending. A new application to sanction two pools is pending. 

ERA had objected to this development, given its ODZ encroachment, and the Superintendence of Cultural Heritage noted with “grave concern” that the development was irreversibly changing the rural area.

In response to Amphora Media’s questions, the developers’ spokesperson said that “the land in question was already scheduled for development. The choice was therefore not between development and leaving the site in its natural state, but between one comprehensive, coordinated development and the possibility of approximately 40 individual plots being developed separately by different owners over time. We are very proud of the resulting

development.”

The spokesperson added that “the relevant fines are being contested and we are currently pursuing the applicable sanctioning process” and that the developers “do not accept the characterisation that [the pools] were simply “illegally developed”, particularly while […] comparable pool developments on ODZ land have been permitted or sanctioned elsewhere in Malta and Gozo.”

No 14:  Airport runway expansion – 12,403.86 m²

This rounds up the largest land use changes on government sites (Central Link, the cemetery, the industrial estate expansion, and the concert grounds).

No 15: Villas and Apartments in Attard: 12,069.56 m²

A large green area in Attard, located behind the American Embassy in Ta’ Qali.

The site was developed across multiple applications and includes villas, terraced houses, and apartment blocks.

No 16. Vista Xlokk, Marsaxlokk: 11,783.35 m²

A housing development in Marsaxlokk called Vista Xlokk ate up several fields. Malta Tourism Authority’s listings show that at least one of the development’s apartments is used as a short-let.

No. 17: The Crest, Sannat: 10,792.49 m²

This development included residential units and pools. Realtors market apartments in the development to those who enjoy “natural surroundings” and “country views”.

While Valletta stands as one of Malta’s most celebrated historical landmarks, an area of green space larger than the UNESCO capital has been lost to construction since 2018.

A new investigation by Amphora Media, in collaboration with Arena for Journalism in Europe and supported by The Malta Environment Foundation, reveals how nearly 830,000 square metres of nature and cropland have been built up in Malta between 2018 and 2023.

That’s about 116 football pitches – or two Manoel Islands – and roughly a quarter of Comino. It’s almost double the entire land area of Vatican City.

The investigation uses methodology established in ‘Green to Grey’, an award-winning investigation into documented green land (nature and cropland) loss in Europe. It was coordinated by Arena for Journalism in Europe and initiated by the Norwegian Broadcasting Corporation (NRK) to quantify for the first time exactly how much nature is being lost to construction in Europe. 41 journalists from 11 countries worked together with scientists from the Norwegian Institute for Nature Research (NINA) to refine their novel methodology. Malta was excluded… until now.

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Malta’s total land loss stands at 0.26%, placing it above the UK and among the top 5 countries by share of green area lost to development. The figure is a conservative estimate as the data uses an AI model to flag potential ‘Green to Grey’ areas.

The largest five areas identified in the research in Malta ranged from over 20,000 to over 34,000 square metres.

The land use changes may seem small on a map and are dispersed across Malta and Gozo. But as Peter Verburg, a professor of environmental spatial analysis at VU University Amsterdam, explained, the cumulative impact is driving global change.

According to figures provided by the European Environment Agency, Malta lost 920,000 square metres of land to development between 2012 and 2018; between 2006 and 2012, Malta lost 190,000 square metres.

Taken together, the data show that since 2006, when the PN government introduced its rationalisation exercise, Malta has lost at least 1.94 square kilometres of green land.

Artificial surfaces are the largest land use category in Malta, followed by cropland, which constitutes another quarter, and shrubland, about one fifth of the land area.

Statistically, around 26% of the Maltese islands’ area is covered by artificial surfaces, and almost 15% is built up as of 2022. 

Source: Eurostat

For comparison, areas enjoying some form of protection under the Natura 2000 framework cover nearly 14% of Malta’s land. Compared to other EU countries, Malta has a low rate of artificial area per resident, meaning that many people are concentrated in relatively small built-up areas.

In the Green to Grey team’s analysis, the Netherlands led in the share of land taken up by construction between 2018 and 2023, with 0.46%. Belgium, Poland, and the UK followed, with 0.25% or more. Countries of the Scandinavian peninsula lost 0.06% or less.

How did we do it?

With guidance from Arena for Journalism in Europe and Green to Grey’s coordinators, Amphora Media replicated the project’s methodology. This consisted of:

1. Using Dynamic World, a land use and land cover dataset produced by Google and the World Resources Institute, employing a deep learning model;
2. Tuning the algorithm to isolate every pixel that changed from not being built-up to being built-up between 2018 and 2023;
3. Manually verifying the model’s output;
4. Calculating the land take-up;
5. Finding case studies.

The team did not manually examine the entire territory of Malta to see whether the algorithm missed any developments, so the calculations and the map of identified land use change are conservative estimates, and some developments may be missing.

This method used satellite images only and did not address whether the land taken up is outside the development zone.

How to use the map

The map outlines the areas that were developed (turned from green to grey) and were detected as such by the algorithm. By scrolling through the map, you can zoom in, select a site, and see how it changed from a satellite view.

The Amphora Media team verified the shapes on the map using satellite imagery. Inaccuracies may occur where satellite images were unclear. The algorithm may have missed some developments because it relied only on satellite imagery. Therefore, use the map as a starting point for further inquiry rather than as conclusive evidence.

This investigation was supported by The Malta Environment Foundation