Appraisal or valuation: who may put a figure on a Queensland home

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Kooky

Builder of Shaka, the payment router that pays every agent their commission on closing date.

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A card in the letterbox offers a free appraisal. A lender's email says a valuation has been ordered. A notice from the State gives the land a value that looks nothing like either. An owner can hold three figures for the same home in the same year, each produced by a different person, under a different law, for a different reader.

The words are often used as if they meant the same thing. In Queensland they do not, and the gap is wider here than elsewhere in the country, because the State keeps its own Act for valuers, its own board and its own register. This guide sets out who may sign each kind of figure, what stands behind it, and which institutions will take it: a lender, the tax office, the revenue office, a court. It does not go back over how an asking price is chosen or how an online estimate is computed, which the magazine has treated separately.

Valuers Registration Act 1992, sections 63 and 30; Office of Fair Trading guidance for sellers, updated 19 July 2024.

Two words that the law keeps apart

The Valuers Registration Board of Queensland, the statutory body that administers the Act, draws the line in plain terms on its own website. A valuation, it says, is the work of a registered valuer, and under the Valuers Registration Act 1992 only a registered valuer may legally value real property in Queensland. The Board adds that assessments of rental value count as valuations too.

An appraisal, in the Board's description, is something else: a broad estimate of what a property might sell or let for, of the kind real estate agents routinely give to sellers, buyers and tenants. The Board states that an appraisal is not a valuation and cannot be relied on for a financial decision or for a legal or statutory purpose.

That is a strong statement, and it is worth reading it next to the Act itself, because the two are not worded the same way. The offence in section 63 is aimed at a person who is not registered and who holds themselves out as a registered valuer, carries on or attempts to carry on the business of a registered valuer, or uses a name, title, description or symbol suggesting registration. The maximum penalty is 100 penalty units. In its own words, then, the section does not make the act of forming an opinion of value an offence: it is aimed at holding out, carrying on the business and using the title. It names no exemption for real estate agents, and needs none for an appraisal that claims to be nothing more. Section 3 defines a valuer broadly, as a person who in any capacity holds themselves out as ready to make a valuation of land.

So the practical boundary for an agent is about what the document claims to be. An agent who gives an opinion of likely selling price, labelled as an appraisal, is doing ordinary agency work under an agency licence. A document presented as a valuation, by someone who is not on the register, is the thing the Act is written to stop.

What it takes to be on the register

Registration is not a formality. Section 30 of the Act requires the Board to register an applicant who is of good fame and character and a fit and proper person, who holds a recognised certificate of competence or has passed an examination approved by the Board, and who has at least three years of practical experience since starting an approved course.

The Board's Guidelines for Registration as a Valuer, approved in April 2024, fill in the detail. The certificate of competence route is open to holders of Certified Practising Valuer status with the Australian Property Institute, as Associate or Fellow, issued from 8 February 2021, and to Chartered Valuation Surveyors of the Royal Institution of Chartered Surveyors. Other applicants take the standard route and must submit a log of their valuation work over the previous 12 months, an employment history, and four sample Queensland valuations, each no more than six months old: one freehold residence, one multi-tenanted income-producing property, one income-producing or specialised property, and one more of a different kind. The guidelines say short-form reports are not accepted as samples. Applicants on this route are interviewed.

Registration then has to be kept alive. Under section 36, the annual roll fee is due before 1 May for the financial year that follows, a late fee applies after 30 April, and registration is cancelled if the fee is still unpaid at 30 June. Section 36B adds a yearly statement of continuing professional development; the guidelines put the minimum at 10 hours a year on property matters.

For an owner, the useful provisions are sections 26 to 28. The Board must keep the Register of Valuers of Queensland, anyone may inspect it at the Board's office, and a copy as at 1 July each year must be published in the gazette and on the Board's website. Checking a name against it takes a few minutes and settles the question of who is entitled to the title.

What the penalty units come to in dollars

Queensland Acts express fines in penalty units so the dollar amounts can be indexed without amending each Act. The Penalties and Sentences (Penalty Unit Value) Amendment Regulation 2026 lifted the unit from $166.90 to $172.70 from 1 July 2026.

On that value, the 100 penalty units in section 63 of the Valuers Registration Act come to a maximum of $17,270. The Act gives the Board the power to prosecute the offence itself, under section 49. Two exceptions are written into section 63: a company is not guilty if at least one of its directors, board members or employees is a registered valuer, and architects, engineers and quantity surveyors may go on making cost estimates in the course of their own professions.

What an agent's appraisal has to rest on

Being outside the valuers' Act does not leave an agent's figure unregulated. It falls under the Property Occupations Act 2014 and the guidance of the Office of Fair Trading, which licenses agents.

The Office of Fair Trading's page for sellers on appointing an agent, last updated on 19 July 2024, and its page for the industry on doing property valuations state the rule a homeowner is most likely to meet. If an agent suggests an asking price, the agent must do a comparative market analysis, usually shortened to CMA. The analysis compares the home with at least three properties of similar standard or condition, sold within 5 kilometres and within the last six months. Where three such sales cannot be found, the agent must instead give the market advice in writing and justify how the opinion was reached.

Behind that sits section 212 of the Property Occupations Act, the general ban on false or misleading representations about property. A legal article published by the Real Estate Institute of Queensland on 27 June 2023 sets out its working parts: a licensee or salesperson must not represent anything false or misleading in relation to the sale, letting or exchange of real property; a representation made without reasonable grounds is taken to be misleading; and it is for the person who made it to show the grounds existed.

Put together, the rules make the free appraisal a document with an evidence requirement. The comparable sales are the reasonable grounds. An owner can ask to see them, and the same Office of Fair Trading page suggests speaking with several agents and asking each to inspect the property before choosing one.

What the appraisal is not is independent. It is given free, by a person who hopes to be appointed and paid a commission on a sale. It does explain why outside institutions treat the document with more or less weight depending on what is at stake.

What a valuation report contains

A valuation is a commissioned piece of professional work, and its shape is set largely by standards. The Australian Property Institute states on its standards page that it adopted the International Valuation Standards word for word in 2007 and that compliance is mandatory for its valuer members. The current edition was released by the International Valuation Standards Council in January 2024 and took effect on 31 January 2025.

The Queensland Government's page for sellers on getting a property valuation, last updated on 29 October 2020, lists what a report may hold: a summary, land and title details, location and a map, a description of the site and its services, town planning information, photographs, a description of the improvements, environmental matters, the basis of valuation with the sales evidence, a review of the market, the final figure, and the valuer's qualifications and disclaimers.

The same page explains that the instruction comes first. The client tells the valuer who they are, whom the valuer is acting for, and why the valuation is wanted, and supplies the address, the legal description if known, a contact for access and the basis of the figure, which is usually market value. Those instructions become the contract: the fee and how it is paid, the date of valuation, the delivery date, and who else may see the report.

On price, the Queensland Government page is direct: there is no set fee for a property valuation, and the fee is to be negotiated with the valuer before work starts. No dated primary source gives a going rate, so none is quoted here. The page also advises choosing an independent valuer over one referred by a party with an interest in the sale, or at least understanding that relationship.

Why the bank's valuation is not yours

When a home loan is assessed, the lender, not the borrower, instructs the valuer. For a standard house or unit the report is usually written on a template owned by the Australian Property Institute and known as the PropertyPRO report. The Institute's protocol on its correct use, published on 10 December 2024 and in effect from 1 January 2025, is unusually specific. The template is for valuing a single residential property for or on behalf of a lender, for first mortgage purposes only. Clients who are not lenders are not permitted. The supporting memorandum excludes, among other uses, marketing advice, pre-purchase valuations, self-managed super fund reporting and family law valuations. The Institute describes the result as a brief report on a single residential property.

The question a lender asks is narrow: is this property adequate security for this loan? The Australian Prudential Regulation Authority's practice guide on residential mortgage lending, APG 223, in the February 2017 version published on its website, says the selection of valuers should sit with a lender's risk management area and not with its sales staff, and describes pressure on a valuer to overvalue as poor practice.

A private valuation, by contrast, is one the owner commissions and pays for. It is typically a longer report, the owner is the client, and the purpose is whatever the instruction says. What happens when a lender's figure comes in under a contract price is a subject of its own and is not repeated here.

Desktop and automated figures

Not every figure a lender uses involves a visit. APG 223 accepts desktop assessments, kerbside assessments, automated valuation models and reviews of the contract of sale "in the appropriate context", with more specialist valuation expected as the risk in the security rises. Its glossary describes a desktop assessment as one made with no physical inspection and a kerbside assessment as an exterior check of location and visible condition. A computer-generated estimate is a statistical output and carries no valuer's signature. The Australian Property Institute's protocol adds that a desktop process is not suitable for producing a PropertyPRO report.

Who will accept which document

The answer to "which one do I need" depends on who will read it, and the readers do not all draw the line in the same place.

Capital gains tax. The Australian Taxation Office's page on market valuation of assets, last updated on 22 June 2026, defines market value as the estimated worth of an asset on the open market at a particular time, based on its most valuable use and on what a willing buyer and seller would agree at arm's length. It names two property situations where a valuation is needed: a transfer between related parties, such as family members, and the day a main residence first starts to be rented or used for business. The page does not require a particular profession, but it says valuations by professional valuers are more credible than those by people who are not, and that a taxpayer who engages and properly instructs a professional valuer will generally not be liable for penalties if the valuation is later found deficient. It lists the minimum contents of a report: purpose, scope, details of the asset, the date, whether the valuation is retrospective, any inspection date, the records behind the figure, and the value.

Deceased estates. The Taxation Office's page on inherited assets, also updated on 22 June 2026, says that where the deceased acquired the asset before 20 September 1985, the person inheriting needs its market value at the date of death. If the legal personal representative had the asset valued, the report can be requested from them; if not, the page suggests obtaining a valuation.

Transfer duty. Here the agent's document does have official standing. Under section 11(7) of the Duties Act 2001, as explained in the Queensland Revenue Office's Public Ruling DA505.1.2, duty is charged on the consideration or the unencumbered value of the property, whichever is higher. The ruling, in force since 3 July 2009, says evidence of value must be provided where the parties are family members, where a party is a company associated with another party, where there is no consideration, or where the consideration cannot be ascertained. It then says the Commissioner will generally accept evidence of market value from registered valuers or from real estate agents who are competent, independent and able to support their opinion with at least three recent comparable sales. The evidence must identify the property by its real property description and street address and describe the improvements, and evidence dated up to three months before the transfer is signed will generally be accepted.

The ruling also explains what happens when the Commissioner is not satisfied and orders a valuation. The cost is passed on only if the declared value proves too low: by more than 10 per cent where the Commissioner's value is up to $1,000,000, or by more than $100,000 where it is above that.

Family law. Guidance published by the Federal Circuit and Family Court of Australia for its priority property pool cases says that if the values of items are agreed, the court may record those values. Where they are not, the parties are asked to try to agree on a valuer, and a judicial registrar may choose one and make orders about who pays. An appraisal may therefore help two people reach an agreed figure, but a contested value goes to an expert.

Compulsory acquisition. The Queensland Government's page on land acquisition, updated on 7 January 2025, says compensation under the Acquisition of Land Act 1967 is based on market value at the date the gazette notice is published, assessed by a valuer. The owner may engage a registered valuer or a solicitor to help with the claim, reasonable costs of preparing and filing it are reimbursed as part of the settlement, the claim must be made within three years of the notice, and either side may take a disagreement to the Land Court.

The State's land value is a third thing

The annual notice from the State is neither an appraisal nor a valuation of the home. The Queensland Government's page on its methods, updated on 9 March 2026, says the figure is a valuation of the land only, not of houses or other structures. Non-rural land is valued on site value and most rural land on unimproved value, the work is done by mass appraisal of many properties at a common date, and the Valuer-General reviews values in selected local government areas each year. Its use is to feed council rates and land tax. It says nothing about what a buyer would pay for the house standing on the land, and it is not evidence of that in any of the settings above.

When something goes wrong

Complaints go to different places, because the two professions answer to different regulators.

About a valuer, or about someone presenting as one, the path is the Valuers Registration Board. Section 43 of the Act lets an aggrieved person complain in writing, and the Board's complaints page provides separate forms for a registered valuer, a specialist retail valuer and an unregistered person. The grounds are professional misconduct, incompetence, negligence or a breach of the code of professional conduct.

The limits are stated just as clearly. The Board cannot award damages or compensation, settle a commercial dispute, mediate, or order a valuation to be set aside or redone. It does not investigate a disagreement over the amount: it looks at the valuer's conduct.

The outcomes run from dismissal, through an educational approach with the valuer, to a formal investigation. After an investigation the Board may act itself under section 51, with a reprimand, an undertaking or a penalty of up to 20 penalty units, which is $3,454 at the current unit value. It may instead refer the matter to the Queensland Civil and Administrative Tribunal, which under section 59 may order up to 100 penalty units, suspend registration for up to 12 months or cancel it. A complainant unhappy with the handling can ask the Queensland Ombudsman to review it.

About an agent's appraisal, the regulator is the Office of Fair Trading, which administers the Property Occupations Act and its rule against representations made without reasonable grounds.

Neither route changes a number. A person who simply disagrees with a figure has one ordinary remedy, which is a second opinion from someone else entitled to give one.

An appraisal is an opinion with its evidence attached. A valuation is an opinion with a registered name and a stated purpose attached.

Kooky, from Shaka

Kooky edits Queensland Estate and builds Shaka, the payment router he made for Queensland property professionals. One payment comes in, and every agent, agency and party in the deal receives their signed share on closing date.

About Kooky and Shaka →