ZA v13.3.0
content: ai_generated 99 sources retrieved model claude-opus-4-8 · 2026-06-23

South Africa

ZA schema world-payments-v1 trajectory: not yet assessed

Last updated · 14 modules · 62 sourced findings · 115 sources in the cumulative register

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Jurisdiction brief

Latest update · 18 October 2026

Lead Signal

South Africa's national payment system governance underwent a structural handover this cycle. The South African Reserve Bank withdrew its recognition of the Payments Association of South Africa as the country's payment system management body, with the underlying functions transferring to SARB from 11 August 2026 and PASA's formal recognition lapsing on 2 September 2026. After 27 years of industry self-regulation under PASA, SARB now directly manages core national payment system functions, a shift the central bank has framed as part of ongoing reforms to modernise the national payment system and keep it safe and efficient. This is not an incident; it is a change in who holds market-access gatekeeping authority for payment institutions operating in South Africa.

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The South African Reserve Bank has taken direct regulatory control of national payment system management, ending PASA's 27-year role as PSMB. From 11 August 2026 key functions, staff and IP began transferring to SARB; PASA's PSMB recognition formally lapsed on 2 September 2026. TPPP registration also moved to SARB's National Payment System Department, with legacy PASA criteria applying pending SARB's draft Authorisation Framework.

Movement — CHANGEDSARB has assumed direct payment-system management control from PASA, effective 11 August 2026, formally completed 2 September 2026Structural regulatory-architecture change in market-access authority this cycle
Horizon · 2026 (±year)South Africa activity-based payment authorisation framework finalisation and first non-bank PI licencesconsultation · T3
Standing sub-brief · as of 23 June 2026449 words · last cycle 2026-10-18

Licensing, Authorisation & Market Access

South Africa's payment licensing baseline rests on the National Payment System Act 78 of 1998 and the SARB Act 90 of 1989, under which the South African Reserve Bank is empowered to manage, regulate and oversee payment, clearing and settlement systems. The NPS Act defines service-provider categories including clearing, settlement and non-clearing banks, designated clearing system participants, PCH system operators, system operators and third-party payment providers. There is currently no PSD2-style standalone EMI or PI licence: deposit-taking requires bank status, defining who may lawfully provide payment services in the country. For non-banks (non-bank PI/EMI), the only current lawful route runs through the Payments Association of South Africa, recognised as a payment system management body by SARB in 1999, which keeps records of all third-party payment providers under SARB Third-Party Provider Directive 1 of 2007; to offer TPPP services a firm must register with PASA through a sponsoring bank, with PASA membership currently reserved for registered banks and designated clearing participants. This sponsor-bank dependency is the structural gatekeeping that the reform aims to dismantle.

Periodic update · new data 2026-10-18

Licensing, Authorisation & Market Access

South Africa's market-access architecture for payment institutions changed structurally this cycle. The South African Reserve Bank withdrew its recognition of the Payments Association of South Africa as the country's payment system management body. The underlying management functions began transferring to SARB from 11 August 2026, and PASA's formal PSMB recognition lapsed on 2 September 2026, ending 27 years in which PASA held this gatekeeping role on an industry-self-regulatory basis. SARB has described the move as part of ongoing reforms to modernise the national payment system and keep it safe and efficient, which frames this as a deliberate architectural choice rather than a response to any specific failure at PASA.

The practical consequence for market access is significant. Any entity seeking to enter South Africa's payment system, whether as a bank or non-bank payment institution, now deals directly with SARB rather than with PASA for the functions that PASA previously managed. This is a shift from an industry self-regulatory body to direct central-bank administration of core national payment system functions, which changes both the institutional character of the gatekeeper and, potentially, the pace and criteria by which market access decisions are made going forward.

The transition is not yet fully settled in its operational detail. SARB has not yet finalised its own draft Authorisation Framework for payment institutions, meaning the specific registration and licensing criteria that will ultimately replace PASA's legacy criteria are not yet public in final form. In the interim, existing registrations remain valid under the old PASA-era criteria, creating a transitional period in which the formal authority has changed hands but the substantive rules governing authorisation have not yet been rewritten.

This transitional ambiguity is not merely theoretical. Nuvei's announcement of local-acquiring authorisation in South Africa, its 52nd market, around 15 October 2026, referenced PASA terminology despite the formal handover to SARB having already taken legal effect over two months earlier. This suggests that market participants, and potentially the public communications function of payment institutions themselves, have not yet fully internalised or clearly communicated which body is now the authorising authority for specific categories of payment activity, such as local acquiring. Whether this reflects genuine residual involvement of PASA-era processes, imprecise public communication by the entrant, or a broader market lag in understanding the new authorisation pathway is not resolved by the evidence available this cycle.

The structural significance of this transition extends beyond the immediate administrative handover. A central bank taking direct control of payment-system management functions previously held by an industry body is the kind of architecture-level shift that typically has downstream effects on licensing pace, supervisory intensity, and the relative influence of industry voice in shaping authorisation criteria, compared to a model in which the industry body itself set and administered those criteria. South Africa's payment institutions, both bank-affiliated and independent, should expect the authorisation landscape to continue evolving as SARB builds out its own direct administrative capacity and framework.

Outlook

The critical near-term milestone is SARB's finalisation of its draft Authorisation Framework for payment institutions, which will set the definitive registration and licensing criteria replacing PASA's legacy approach. Until that framework is finalised, authorisation processes for new entrants will likely continue to carry some degree of procedural ambiguity, as illustrated by the Nuvei episode, where the entrant itself appeared uncertain or imprecise about which body and process now governs its authorisation. Market participants evaluating entry or expansion in South Africa's payment system should anticipate a period of continued transition before the new framework provides full clarity on authorisation criteria and process.

5 earlier distinct update(s)
Periodic update · new data 2026-10-11

Licensing, Authorisation & Market Access

South Africa's payments-licensing perimeter is in the midst of a structural transition away from its historical bank-sponsorship model. The South African Reserve Bank published a third draft of its Authorisation Framework on 22 May 2026, with the comment period closing 15 June 2026. The framework would move the regime to activity-based authorisation, covering e-money issuance, acquiring and payment execution as distinct licensable activities, rather than requiring non-bank payment service providers to operate under a sponsoring bank's licence. This is a material change in market-access architecture for non-bank payment institutions and e-money institutions operating or seeking to operate in South Africa.

Draft provisions reported this cycle include a Category 2 Acquiring minimum capital requirement of ZAR 3,000,000, applied without tiering by size or transaction volume, and a Category 3 Payment Execution category that would require direct designation by the Reserve Bank rather than operating through an intermediary's existing authorisation. These figures and category structures come from draft-framework reporting and have not been confirmed as final; the framework remains subject to revision between the third draft and any eventual final publication.

The Reserve Bank has indicated an intent to publish the final Authorisation Framework in the third quarter of 2026, but that finalisation has not been independently confirmed this cycle. Until the framework is finalised, the practical licensing pathway for non-bank payment service providers in South Africa continues to depend on the bank-sponsorship arrangements the new framework is designed to replace, meaning current market entrants face a transitional period of uncertainty over which regime will ultimately govern their authorisation.

Outlook

The Reserve Bank's indicated Q3 2026 publication target for the final Authorisation Framework has not yet been confirmed as met or missed, and the practical consequences of the shift to activity-based licensing, including final capital requirements across all authorisation categories, remain to be settled by the final instrument. Non-bank payment service providers currently operating under bank-sponsorship arrangements face a transition period whose length depends on when, and in what final form, the framework is published.

Periodic update · new data 2026-10-04

Licensing, Authorisation & Market Access

The South African Reserve Bank has concluded the withdrawal of the Payments Association of South Africa's recognition as a payment system management body, with the withdrawal taking effect on 2 September 2026. This formally ends an arrangement under which PASA, an industry body, held delegated recognition to perform payment-system management-body functions including rule-making and administration of certain authorisation and registration processes within South Africa's National Payment System. SARB's own transition notice states that structural and operational challenges associated with the PSMB model necessitated the decision, framing the move as a response to persistent institutional limitations in the self-regulatory arrangement rather than a response to any single incident.

The functions previously exercised through PASA's PSMB recognition now sit directly within SARB's National Payment System Department, specifically its Policy, Regulation and Licensing Division. This is a genuine structural consolidation: authorisation and registration authority over payment system participants, previously mediated through an industry body operating under delegated recognition, now runs directly from the central bank. For firms operating in South Africa's payment ecosystem, the practical consequence is a single point of regulatory contact for NPS authorisation matters going forward, replacing a two-tier arrangement in which PASA handled much of the day-to-day administration under SARB's overarching statutory authority.

A critical point for market participants, and one corroborated independently of SARB's own notices, is that the licensing categories themselves, Payment System Operator, System Operator, and Third-Party Payment Provider, are unchanged by this transition. Only the administering body has changed. This means the substantive requirements firms must meet to hold PSO, SO, or TPPP status are not altered by the PASA-to-SARB shift; what has changed is which institution processes applications, administers the rulebook, and exercises day-to-day oversight. Existing authorisations are understood to remain valid through the transition, meaning currently-licensed participants do not face an immediate re-authorisation burden as a direct result of this administrative change.

The structural significance of this development exceeds its administrative framing. Industry self-regulation of core payment-system functions, sustained for close to three decades through PASA's PSMB recognition, has now given way to direct central-bank administration. This is the kind of architecture-level shift that outlasts any single enforcement action or licensing decision: it changes who sets the rules and who polices them for every PSO, SO, and TPPP operating in South Africa, on a continuing basis rather than as a one-off event.

Outlook

The immediate practical question for licensed and prospective payment system participants is how SARB's Policy, Regulation and Licensing Division chooses to operationalise the functions it has absorbed. Because the underlying licence categories are unchanged, firms do not face a substantive compliance gap, but they should anticipate that rulebook administration, application processing timelines, and day-to-day engagement on authorisation matters will now run through SARB's own department rather than through PASA's prior industry-body channels. Whether SARB issues updated procedural guidance distinct from PASA's prior practice, or substantially continues existing administrative conventions under new management, will determine how smoothly the transition proceeds in practice for PSO, SO, and TPPP holders navigating the shift away from industry self-regulation.

Periodic update · new data 2026-09-29

Licensing, Authorisation & Market Access

The South African Reserve Bank withdrew the Payments Association of South Africa's recognition as the country's Payment System Management Body, effective 2 September 2026, following a directive issued 2 June 2026 that provided three months' notice. This is a structural change to how payment institutions are licensed and authorised in South Africa: authority that had sat with PASA, an industry self-regulatory body, for nearly three decades now sits directly with the central bank. Licensing, authorisation and registration of payment institutions moves from a model overseen by the banks themselves to one directly administered by SARB, ending the self-regulatory arrangement that had governed market access to South Africa's payment system since PASA's establishment. This is the dominant payments development identified for South Africa this cycle, and it carries direct market-access implications for any entity seeking to participate in electronic funds transfer, DebiCheck, PayShap or real-time clearing arrangements, since the licensing gatekeeper for those arrangements has changed.

Outlook

The transition took effect 2 September 2026. The next marker to watch is how SARB exercises its newly consolidated licensing and authorisation authority in practice, including whether authorisation criteria or timelines for new payment institution entrants change under direct central-bank administration compared to the prior PASA-administered model.

Periodic update · new data 2026-09-22

Licensing, Authorisation & Market Access

The South African Reserve Bank withdrew the Payments Association of South Africa's recognition as Payment System Management Body, effective 2 September 2026, following a transition period that began 11 August 2026. This is a Confirmed, Tier-1 development sourced directly from a South African Government News Agency release, and it ends 27 years of bank-led self-regulation of the National Payment System, with licensing, authorisation and registration functions previously delegated to PASA now assumed directly by SARB. In parallel, the National Payment System Act 78 of 1998 is targeted for amendment in 2026 to enable an activity-based non-bank licensing regime, which would open the National Payment System to non-bank payment service providers for the first time; this finding is Probable, sourced from industry commentary rather than a primary legislative text.

Alongside the governance transition, a new registration requirement has been introduced for closed-loop payment systems, with an exemption for systems processing below R15 million per year or serving fewer than one million customers, and third-party processors are now capped at two beneficiary accounts. This is Probable, sourced from technology-press reporting on the underlying National Payment System Act amendment package. The combined effect of these developments is a bifurcated trajectory: licensing and rule-making authority is centralising under SARB even as the market-access door is being opened wider to non-bank entrants through the planned activity-based licensing regime.

Outlook

The central marker for the next cycle is whether the National Payment System Act amendment enabling activity-based non-bank licensing proceeds on the 2026 timeline suggested by industry commentary, and what specific licence categories and capital or operational requirements accompany it. Confirmation of the closed-loop registration thresholds directly from SARB or National Treasury, rather than technology-press reporting, would raise confidence in the specific R15 million and one-million-customer figures.

Periodic update · new data 2026-08-26

Licensing, Authorisation & Market Access

South Africa's payments-licensing architecture is moving from a bank-sponsorship-dependent model toward direct, activity-based authorisation for non-bank payment institutions. The South African Reserve Bank's draft exemption notice and Authorisation Framework, an Assessed-confidence finding, would allow payment institutions to self-authorise against defined activity categories rather than operating solely under a sponsoring bank's licence; the public consultation closed for comment on 15 June 2026, with the finalised framework expected in the third quarter of 2026. This is a structural market-access change: non-bank payment service providers, previously dependent on bank sponsorship arrangements to access the National Payment System, would gain a more direct authorisation pathway, narrowing though not eliminating the bank-PSP versus non-bank-PI/EMI distinction that has historically shaped South African market access.

The reform sits inside a broader strategic refresh: the Reserve Bank published a Vision 2030+ consultation paper in February 2026, building on the prior Vision 2025 framework and adding an explicit inclusive-growth-and-development goal, an Assessed-confidence signal that the Authorisation Framework reform is part of a multi-year strategic direction rather than an isolated rule change. Both developments remain in draft or consultation form; the interpreter's own gaps register notes that no direct SARB.co.za or Government Gazette URL was retrieved for the Authorisation Framework text this cycle, meaning the specifics rest on secondary legal and trade-press reporting rather than primary regulatory text.

Outlook

The consultation's 15 June 2026 close and the third-quarter-2026 expected finalisation are the two dates to track; whether the final framework preserves activity-based self-authorisation as drafted, or reintroduces bank-sponsorship conditions during finalisation, will determine the practical scope of non-bank market access. Retrieval of a primary SARB or Government Gazette text for the Authorisation Framework would materially improve confidence above the current Assessed tier.

Sources and findings (5)
  1. T1SARB Authorisation Framework & Exemption Notice for Payment Activities (draft, Nov 2025) (resbank.co.za)
  2. T1SARB Draft Directive — activity-based authorisation; PA Prudential Communication 10 of 2026 (resbank.co.za)
  3. T3https://bowmanslaw.com/insights/the-south-african-reserve-bank-has-recently-published-a-draft-activity-based-authorisation-framework-for-participants-banks-and-non-banks-in-the-national-payment-system/ [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]
  4. T3https://facephi.com/en/national-payment-system-south-africa-psp-licences/ [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]
  5. T2https://authorisation.pasa.org.za/so-and-tppp/tppp-registration/retrieved

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Conduct and consumer-protection supervision is split under the Twin Peaks model: the SARB Prudential Authority (PA) is the prudential supervisor and the Financial Sector Conduct Authority (FSCA) is the market-conduct authority, both operating under the Financial Sector Regulation Act 2017. The current safeguarding position is that only banks may take deposits, so non-bank payment safeguarding has historically depended on sponsor-bank arrangements; the proposed activity-based regime introduces explicit fund-segregation, minimum-capital and AML obligations for non-bank payment institutions. The FSCA also supervises financial products under the FAIS Act (including crypto assets declared financial products in 2022). Sponsorship arrangements are being preserved but on a more structured, accountability-based footing.

Standing sub-brief · as of 23 June 2026241 words · last cycle 2026-06-23

Conduct, Safeguarding & Promotions

South Africa operates a Twin Peaks supervisory architecture established by the Financial Sector Regulation Act 2017: the SARB Prudential Authority is the prudential supervisor and the FSCA is the market-conduct authority, with section 107 of the FSR Act empowering joint standards. This split defines the conduct and customer-fund-protection obligations payment operators face. The FSCA declared crypto assets financial products under the FAIS Act in 2022, which brings crypto-asset service providers into the conduct perimeter only — it does not amount to NPS payment-services authorisation.

no periodic updates on record for this sub-brief

Sources and findings (4)
  1. T2https://www.ebnet.co.za/fsca-publishes-final-joint-standard-on-cybersecurity-and-cyber-resilience-requirements-for-financial-institutions/retrieved
  2. T3https://facephi.com/en/national-payment-system-south-africa-psp-licences/ [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]
  3. T3https://www.mondaq.com/southafrica/financial-services/1802450/third-party-payment-providers-at-a-regulatory-crossroads [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]
  4. T3https://bitcoinke.io/2026/06/legal-clarity-on-crypto-assets-in-south-africa/ [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]

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South Africa has no dedicated stablecoin/e-money issuance framework in force: under the long-standing SARB 2009 Electronic Money position paper only registered banks may issue e-money, so a non-bank stablecoin falls outside the domestic e-money definition. On 28-29 May 2026 SARB, the FSCA, the Prudential Authority and the FIC issued Joint Communication 1 of 2026 clarifying that crypto assets including stablecoins are not money, funds, legal tender or payment instruments under the NPS Act, and crypto used for payments falls outside NPS regulation. The FSB assessed South Africa as having 'no framework in place' for global stablecoin arrangements. Stablecoin trading has surged (to ~R80bn by Oct 2025), and authorities are studying rand-backed stablecoins via the IFWG and the SARB regulatory sandbox while warning that foreign-currency stablecoins pose a dollarisation/monetary-sovereignty risk. The activity-based reform would enable non-banks to issue e-money.

Standing sub-brief · as of 23 June 2026346 words · last cycle 2026-10-11

Stablecoins & Digital Money

The digital-money perimeter in South Africa is defined by two reinforcing constraints and one widening gap. First, under SARB's 2009 Electronic Money position paper (NPS 01/2009), only registered banks may issue e-money, which automatically excludes a non-bank stablecoin from the domestic e-money definition; only registered banks keep reserves with SARB. This is a bank-PSP constraint that the activity-based reform would change by enabling non-bank e-money issuance.

Periodic update · new data 2026-10-11

Stablecoins & Digital Money

A joint communication from the South African Reserve Bank, Financial Sector Conduct Authority, Prudential Authority and Financial Intelligence Centre, Joint Communication 1 of 2026, dated 28 May 2026, confirmed that crypto assets, including stablecoins, are not money or legal tender and fall outside the National Payment System Act for domestic payment purposes. This is a confirmed primary-regulator position establishing that stablecoins used domestically do not benefit from, or fall under, National Payment System Act oversight as a recognised payment instrument.

That position was placed under direct tension within days by a court ruling. In Mangundhla and Another v South African Reserve Bank and Others, decided 1 June 2026, the Gauteng High Court found that Bitcoin is both money and capital for purposes of South Africa's exchange-control framework. The payments-law classification (not money, not legal tender, outside the National Payment System Act) and the exchange-control jurisprudence (Bitcoin is money and capital) now stand in open tension, each governing a different regulatory purpose but both bearing on how crypto assets, including stablecoins, are treated when they cross borders or are exchanged domestically.

Luno's September 2026 launch of instant stablecoin minting for corporate clients, in partnership with the US-regulated clearinghouse Meridian, proceeds against this unresolved backdrop. The product targets institutional and corporate clients rather than domestic retail payment use, which may reduce its direct exposure to the National Payment System Act non-money classification, but the underlying interpretive tension between payments law and exchange-control law remains unresolved for any stablecoin activity that crosses South Africa's borders.

Outlook

The interpretive tension between the Joint Communication's payments-law classification and the Mangundhla exchange-control finding is the central unresolved question for stablecoin and digital-money activity in South Africa going forward. How this tension is resolved, whether through appeal of the Mangundhla decision, through amendment of the Joint Communication's scope, or through the pending Capital Flow Management Regulations addressing cross-border crypto activity specifically, will materially shape the compliance posture required of stablecoin issuers and users operating cross-border from South Africa.

1 earlier distinct update(s)
Periodic update · new data 2026-08-26

Stablecoins & Digital Money

South Africa's crypto-asset regulatory perimeter shifted materially this cycle through the convergence of a joint regulatory communication and a High Court ruling. Joint Communication 1 of 2026, issued by the South African Reserve Bank, the Financial Sector Conduct Authority, the Prudential Authority, and the Financial Intelligence Centre, clarifies the regulatory treatment of crypto assets used domestically for payment purposes, a High-impact, Assessed-confidence development. Separately, the Gauteng Division High Court, in Mangundhla v SARB, ruled that Bitcoin is both money and capital for South African exchange-control purposes, a Critical-impact finding by the interpreter's own scoring, though both findings rest on Tier 3 secondary legal-commentary sourcing rather than directly retrieved primary regulatory or judicial text.

National Treasury's draft Capital Flow Management Regulations, intended to replace the 1961 Exchange Control Regulations, would formally bring crypto assets into the exchange-control framework; the comment period was extended to June 2026, a High-impact but Low-confidence finding sourced to Tier 4 commentary. The South African Revenue Service separately implemented the Crypto Asset Reporting Framework on 1 March 2026, increasing cross-border tax information sharing on crypto transactions, an Elevated-impact, Low-confidence development. Taken together, these data points describe a jurisdiction moving, across payment-regulatory, judicial, exchange-control, and tax-reporting channels simultaneously, toward treating crypto assets as subject to capital controls rather than as an unregulated instrument class, though the underlying legal texts have not yet been directly retrieved to confirm the secondary reporting in full.

Outlook

Finalisation of the draft Capital Flow Management Regulations, targeted around mid-2026, is the key marker for how far the exchange-control perimeter will extend over crypto assets in practice. Any appellate development in the Mangundhla litigation would also be significant, since the High Court ruling is the judicial anchor for treating Bitcoin as capital under exchange control.

Sources and findings (5)
  1. T1https://www.resbank.co.za/content/dam/sarb/what-we-do/financial-stability/The%20financial%20stability%20considerations%20of%20stablecoins.pdfretrieved
  2. T1https://bitcoinke.io/2026/06/legal-clarity-on-crypto-assets-in-south-africa/retrieved
  3. T2https://www.moonstone.co.za/sarb-adds-crypto-and-stablecoins-to-new-financial-stability-risk-category/retrieved
  4. T3https://bitcoinke.io/2026/06/crypto-is-not-money-in-south-africa/ [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]
  5. T3https://www.moneyweb.co.za/moneyweb-crypto/south-africa-flags-crypto-stablecoins-as-new-financial-risk/ [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]

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SARB has withdrawn recognition of PASA as the Payment System Management Body, transferring rule-making, licensing, authorisation and registration functions to SARB itself and to PayInc, effective 2 September 2026, as part of the Payments Ecosystem Modernisation Programme under Vision 2025/2030+.

Kept on Dataprotection.gi, not restated here: data and cloud switching obligations on service providers, including notice periods and charges. Open this jurisdiction's page on Dataprotection.gi →

Standing sub-brief · as of 23 June 2026258 words · last cycle 2026-09-28

Operational Resilience & Critical Infrastructure

Operational resilience for South African payment participants is now governed by two layered, in-force instruments that together form the country's analogue to DORA and PS21-3. The Directive on Cybersecurity and Cyber-resilience within the NPS 1 of 2024, issued 17 May 2024 with compliance required from 17 August 2024, mandates governance, critical-asset identification and controls aligned to ISO 27001 and NIST CSF v2, quarterly testing including third-party and cloud providers, recovery of critical systems within two hours (maximum eight hours), and incident reporting to SARB within 24 hours plus a detailed report within 48 hours. These are binding operational-resilience and incident-reporting obligations for all NPS participants, including third-party and cloud providers, applying to both bank PSPs and non-banks, and they represent a material compliance cost and design constraint.

Periodic update · new data 2026-09-29

Operational Resilience & Critical Infrastructure

South Africa's payment-system governance overhaul is a direct operational-resilience development. As the South African Reserve Bank assumes direct authority following the withdrawal of PASA's Payment System Management Body recognition, effective 2 September 2026, SARB has publicly committed that everyday payment services, including card payments, electronic transfers, debit orders, PayShap and ATM withdrawals, will continue uninterrupted during the transition. This public commitment, made via SARB's own official channel, positions continuity of critical payment infrastructure as a core deliverable of the transition rather than an incidental outcome, reflecting the elevation of payments as a financial-stability pillar in SARB's own strategic framing. The transition itself, moving operational responsibility for electronic funds transfers, DebiCheck, PayShap and real-time clearing from PASA to PayInc, is the specific infrastructure change underlying this resilience commitment; PayInc is positioned as the operating entity taking on these functions with direct SARB ownership involvement.

Outlook

Whether SARB's no-disruption commitment holds through the practical operational handover from PASA to PayInc is the key resilience marker to watch in the near term. Any reported service interruption to card payments, EFTs, debit orders, PayShap or ATM access during the transition period would be the clearest signal that the commitment was not fully met.

Sources and findings (4)
  1. T2https://www.michalsons.com/blog/sarb-cybersecurity-and-cyber-resilience-directive/78268retrieved
  2. T3https://www.mondaq.com/southafrica/security/1601204/ensuring-cybersecurity-and-resilience-navigating-the-sarb-cybersecurity-directive-and-joint-standards-for-financial-institutions [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]
  3. T2https://www.ebnet.co.za/fsca-publishes-final-joint-standard-on-cybersecurity-and-cyber-resilience-requirements-for-financial-institutions/retrieved
  4. T3https://www.moneyweb.co.za/news/south-africa/sarb-bolsters-defences-against-cyberattacks/ [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]

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Card-scheme compliance combines global scheme rulebooks (Visa Core Rules / Mastercard rules) and PCI DSS administered by the PCI Security Standards Council, applied to South African issuers, acquirers, service providers and merchants under the standard four-party model. Distinctively, interchange in South Africa is regulated by SARB via a facilitated interchange determination process (Position Paper 02/2022), reflecting recommendations from the original Competition Commission Banking Enquiry; SARB sets interchange to promote cost-efficiency, interoperability, secure electronic payments and financial inclusion. PCI DSS merchant levels are set by transaction volume (Level 1 >6m/year requiring external audit; lower levels via SAQ), and PCI compliance is also relevant to POPIA obligations. Surcharging is governed by scheme rules and local law.

Standing sub-brief · as of 23 June 2026273 words · last cycle 2026-09-28

Scheme & Network Compliance

South Africa's scheme and network compliance layer combines a distinctive central-bank-facilitated interchange regime with the standard global four-party scheme and PCI model. SARB's Interchange Position Paper 02/2022 establishes that the central bank facilitates interchange determination to minimise interchange abuse, with objectives of cost-efficiency, secure electronic-payments adoption, interoperability, competition and innovation, transparency and financial inclusion. Interchange may be set bilaterally, multilaterally by schemes such as Visa and Mastercard, or via SARB facilitation, with the process originating from the Competition Commission Banking Enquiry. This central-bank-facilitated interchange directly shapes acquirer economics and merchant fees, with SA credit-card interchange historically higher than EU or Australian levels, and it applies across bank and non-bank participants.

Periodic update · new data 2026-09-29

Scheme & Network Compliance

Governance of South Africa's core payment scheme and network arrangements, electronic funds transfers, DebiCheck, PayShap and real-time clearing, transferred from the Payments Association of South Africa to PayInc, effective 2 September 2026, as part of the South African Reserve Bank's withdrawal of PASA's Payment System Management Body recognition. PayInc, the entity formerly operating as BankservAfrica and now carrying a direct SARB ownership stake, assumes the operational role PASA previously held for these scheme arrangements. Standards-setting for these schemes, which had been exercised through PASA's self-regulatory structure for close to three decades, now sits directly with SARB. This represents a consolidation of scheme-rule-making authority previously distributed across an industry body into a single central-bank-administered framework, with direct implications for how scheme compliance requirements for EFT, DebiCheck, PayShap and real-time clearing participants will be set and enforced going forward.

Outlook

The practical question for scheme participants is how SARB's direct standards-setting authority translates into scheme rule changes, if any, once the PayInc operational handover has fully settled following the 2 September 2026 transition date.

1 earlier distinct update(s)
Periodic update · new data 2026-09-22

Scheme & Network Compliance

Following PASA's withdrawal as Payment System Management Body, standardisation responsibility for PayShap, QR-code and payment-initiation technical standards moves to a direct SARB/PayInc work programme, alongside the planned sunset of the Real-Time Clearing system. This is a Probable finding, sourced from technology-press reporting on the underlying National Payment System Act amendment package, and it represents a scheme-governance handover rather than a change to the technical standards themselves at this stage. Because this governance arrangement is newly established, following 27 years of PASA-led self-regulation, there is no multi-cycle supervisory record yet for how SARB and PayInc will exercise this direct scheme-governance role.

The practical significance for scheme participants is that rule-change proposals for PayShap and related instant-payment infrastructure will now be channelled through SARB/PayInc rather than through PASA's former self-regulatory structure, a change in governance process that scheme participants should track closely during this transition period.

Outlook

The key marker to watch is the first substantive PayShap or QR-standard rule change issued under the new SARB/PayInc governance arrangement, which would establish an early precedent for how technical standardisation will operate going forward. The Real-Time Clearing sunset timeline, if and when SARB/PayInc publish one, is a second marker with direct implications for scheme participants still relying on that legacy clearing mechanism.

Sources and findings (4)
  1. T1https://www.resbank.co.za/content/dam/sarb/what-we-do/payments-and-settlements/regulation-oversight-and-supervision/regulatory-and-oversight-reports/Position%20Paper%20no%2002_2022%20on%20Interchange_final%20published%20version.pdfretrieved
  2. T2https://www.visa.co.za/partner-with-us/pci-dss-compliance-information.htmlretrieved
  3. T3https://netcash.co.za/blog/what-south-african-businesses-need-to-know-about-pci-dss/retrieved
  4. T1http://www.compcom.co.za/wp-content/uploads/2014/09/Interchange-determination.pdfretrieved

#

South Africa is the largest remittance send-market in Africa, with principal corridors to SADC neighbours (Zimbabwe being by far the largest by volume and value). Cross-border remittances operate via Authorised Dealers with Limited Authority (ADLAs) under a tiered four-category licensing framework, under strict exchange controls per the ADLA Manual requiring full transaction information; an estimated ~50% of SA-to-SADC remittances still flow through informal channels. Regional rails comprise SARB-operated SADC-RTGS (live since 2013, settling in ZAR, 16-country membership) for high value, and the TCIB scheme (live since 2021) for low-value ISO 20022 retail flows across six corridors. SARB Directive 1 of 2025 requires all low-value cross-border EFTs within the Common Monetary Area (SA, Lesotho, Eswatini, Namibia) to migrate to TCIB by March 2027. Continental integration is via PAPSS (AfCFTA), with which TCIB is intended to interconnect.

Horizon · 2027-Q1 (±quarter)TCIB mandatory migration for low-value cross-border CMA EFTsadopted · T3
Standing sub-brief · as of 23 June 2026343 words · last cycle 2026-06-23

Payment Corridor Dynamics

South Africa is the largest remittance send-market in Africa, with flows directed mainly to the SADC region. Cross-border remittances operate through Authorised Dealers with Limited Authority under a tiered four-category licensing framework and strict exchange controls per the ADLA Manual, which requires full transaction information. This is a non-bank PI/EMI route under formal authorisation. An estimated 50% of SA-to-SADC remittances flow through informal channels, and sub-Saharan Africa remains furthest from the G20 Roadmap targets, with some corridors exceeding 10% cost. The high informal-channel share and high corridor cost represent the core formalisation and cost-reduction opportunity for non-bank remittance operators. Zimbabwe is the dominant corridor: in the year to end-October 2024 it received 8.5 million formal remittance transactions worth R11.8 billion, served by operators including Mukuru, Sikhona and Mama Money.

no periodic updates on record for this sub-brief

Sources and findings (5)
  1. T1https://www.resbank.co.za/en/home/what-we-do/payments-and-settlements/SADC-RTGSretrieved
  2. T1SARB Directive 1 of 2025 — CMA low-value EFT migration to TCIB (resbank.co.za)
  3. T1https://www.resbank.co.za/en/home/publications/publication-detail-pages/media-releases/2025/g20-cross-border-paymentsretrieved
  4. T3https://old.remitscope.org/africa/south_africaretrieved
  5. T1https://www.resbank.co.za/content/dam/sarb/what-we-do/payments-and-settlements/cross-border-payments-conference/documents/paper-sa-sadc.pdfretrieved

#

South Africa's payments market is highly concentrated and bank-dominated: the six largest banks hold more than 90% of sector assets, and the 'big four' (Absa, FNB, Nedbank, Standard Bank) have historically held exclusive control of clearing and settlement. A wave of consolidation and structural change is underway: SARB acquired a 50% stake in PayInc (formerly BankservAfrica), the national clearing operator, in November 2025 as the base for a public National Payment Utility (NPU); Nedbank acquired iKhokha and Lesaka Technologies acquired Adumo and Bank Zero, while Capitec launched its own merchant solution. Non-bank acquirers (Yoco ~35-40% of the independent SME card-acceptance segment, iKhokha, Adumo) and digital banks (TymeBank, Bank Zero) are reshaping the competitive landscape, which the activity-based reform is designed to open further.

Standing sub-brief · as of 23 June 2026298 words · last cycle 2026-06-23

Industry Structure & Commercial

The structural backdrop is a highly concentrated, bank-dominated market. SARB's Financial Stability Review describes the financial sector as very concentrated, particularly banking, where the six largest banks account for more than 90% of sector assets — a situation persisting over a decade and flagged as a new structural vulnerability. The big four (Absa, FNB, Nedbank and Standard Bank) historically held exclusive control of clearing and settlement, defining the competitive landscape that non-bank entrants and reform aim to disrupt.

no periodic updates on record for this sub-brief

Sources and findings (4)
  1. T2https://www.moonstone.co.za/sarb-adds-crypto-and-stablecoins-to-new-financial-stability-risk-category/retrieved
  2. T3https://werksmans.com/payments-revolution-what-every-psp-operating-in-south-africa-needs-to-know-right-now/
  3. T3https://en.wikipedia.org/wiki/Yocoretrieved
  4. T3https://businessmodelcanvastemplate.com/blogs/competitors/yoco-competitive-landscaperetrieved

The most consequential payments-related litigation concerns whether crypto assets fall within South Africa's exchange-control framework. In the 2025 Standard Bank of South Africa v SARB matter the High Court held that crypto is neither 'currency' nor 'capital' under the Exchange Control Regulations and set aside SARB's forfeiture order; SARB obtained leave to appeal to the Supreme Court of Appeal, suspending the ruling. In a contrasting 1 June 2026 judgment, Mangundhla v SARB, the Gauteng High Court held that Bitcoin constitutes both 'money' and 'capital' for exchange-control purposes, so transferring it offshore is an export of capital potentially requiring approval. On enforcement, the Prudential Authority imposed administrative sanctions in the 2025 financial year on banks Capitec (R56m penalty), Standard Bank (R13m) and HSBC for non-compliance.

Horizon · 2026 (±year)Draft exchange-control regulations bringing crypto assets within the frameworkproposed · T3
Standing sub-brief · as of 23 June 2026284 words · last cycle 2026-10-11

Legal & Litigation

The central legal development is a pair of directly conflicting High Court rulings on whether crypto is capital or money under exchange control. On 1 June 2026 the Gauteng High Court held in Mangundhla and Another v SARB that Bitcoin constitutes both money and capital for South Africa's exchange-control framework; the case involved roughly 1,680 Bitcoin transferred to offshore exchange wallets, and the court held such transfers amount to export of capital that may require exchange-control approval.

Periodic update · new data 2026-10-11

Legal & Litigation

The Gauteng High Court's decision in Mangundhla and Another v South African Reserve Bank and Others, handed down 1 June 2026, found that Bitcoin is both money and capital for purposes of South Africa's exchange-control framework. This finding arose in an exchange-control context, interpreting the Exchange Control Regulations, 1961, rather than payments or financial-services legislation directly, but its practical effect reaches into the payments-regulatory space because it stands in direct tension with the South African Reserve Bank, Financial Sector Conduct Authority, Prudential Authority and Financial Intelligence Centre joint communication issued just days earlier, on 28 May 2026, which classified crypto assets, including stablecoins, as not money or legal tender and outside the National Payment System Act.

This creates an unresolved interpretive conflict: the same asset, Bitcoin, is treated as money and capital for exchange-control purposes by the courts, while being treated as neither money nor legal tender for domestic payments purposes by the financial-sector regulators acting jointly. The ruling does not purport to override the Joint Communication, and the Joint Communication does not address exchange-control treatment directly, so the two positions currently coexist as separate findings addressing separate regulatory questions, without an authoritative resolution reconciling them.

Outlook

Whether the Mangundhla finding is appealed, and whether any appellate outcome narrows or confirms its exchange-control reasoning, is not yet known. In the meantime, the tension between the exchange-control and payments-law characterisations of Bitcoin, and by extension other crypto assets, is likely to remain a live source of interpretive uncertainty for any cross-border crypto transaction touching South Africa's exchange-control perimeter, particularly as the draft Capital Flow Management Regulations addressing cross-border crypto activity move toward an outcome following their 30 September 2026 comment-period close.

Sources and findings (4)
  1. T2https://bitcoinke.io/2026/06/legal-clarity-on-crypto-assets-in-south-africa/retrieved
  2. T3https://mayet.law/crypto-regulation-in-south-africa-exchange-control-rules-and-the-sbsa-decision/retrieved
  3. T3https://www.moneyweb.co.za/news/south-africa/sarb-bolsters-defences-against-cyberattacks/retrieved
  4. T3https://www.bakermckenzie.com/en/insight/publications/2026/03/south-africa-crypto-assets-likely-to-enter-exchange-control-regimeretrieved

#

Merchant acquiring follows the standard four-party model with the acquiring bank/PSP supplying the terminal and settling funds net of fees to the merchant. The acquiring market has shifted substantially from bank-only provision (Absa, Standard Bank, Nedbank) toward fintech acquirers and aggregators - Yoco, iKhokha, Adumo, Flash and Capitec - offering pay-as-you-go and SoftPOS/tap-on-phone onboarding with rapid, low-friction merchant sign-up. Merchant risk, onboarding/PCI obligations, chargeback/dispute mechanics and high-risk-MCC treatment flow through scheme rules incorporated into acquiring agreements, with scheme fines passed from networks to acquirers and on to merchants via indemnification. The activity-based reform recognises 'payment acquiring' as a licensable non-bank activity, expected to compress acquiring fees.

Standing sub-brief · as of 23 June 2026192 words · last cycle 2026-06-23

Merchant Acquiring & Risk

South African merchant acquiring follows the four-party model, with the acquiring bank or PSP supplying terminals and settling net of fees. The market has shifted from bank-only provision (Absa, Standard Bank, Nedbank) toward fintech acquirers and aggregators — Yoco, iKhokha, Adumo, Flash and Capitec — offering pay-as-you-go and SoftPOS/tap-on-phone onboarding. This is a non-bank PI/EMI-led transition. Yoco saw 40% of new merchant sign-ups in early 2026 via app-only SoftPOS, illustrating a SoftPOS-led informal-to-formal transition. Scheme fines pass from networks to acquirers to merchants via indemnification, a risk-allocation feature of the model.

no periodic updates on record for this sub-brief

Sources and findings (4)
  1. T3https://eezipay.com/pos-system-card-machine-south-africa/retrieved
  2. T3https://www.pxp.io/payments-glossary/card-scheme-rulesretrieved
  3. T3https://www.decta.com/company/media/how-visa-and-mastercard-ensure-compliance-for-acquirers-and-issuersretrieved
  4. T3https://businessmodelcanvastemplate.com/blogs/competitors/yoco-competitive-landscaperetrieved

#

Product development is led by the SARB Payments Ecosystem Modernisation (PEM) Programme (launched September 2025, succeeding Vision 2025), built around a public National Payment Utility, a new domestic and regional RTGS, an enhanced fast payment system, alternative messaging networks, a QR+ interoperability standard and PEMKey credentials. The domestic instant rail is PayShap (launched 2023 on the Rapid Payments Programme, ISO 20022), which by late 2025 had over 5 million ShapIDs and ~45 million transactions/month (80% under R500); the per-transaction limit was raised to R50,000. Capitec Pay launched the first bank open API in 2023. On CBDC, SARB (via Project Khokha) has deprioritised a retail digital rand, with Deputy Governor Cassim (June 2026) stating the priority is modernising payment 'plumbing'; SARB also intends to introduce an open banking/open finance framework and enable non-bank e-money issuance.

Standing sub-brief · as of 23 June 2026343 words · last cycle 2026-09-14

Product Innovation & Market Development

Product innovation in South Africa is organised around the Payments Ecosystem Modernisation Programme, launched September 2025 to succeed Vision 2025. PEM is built around a public National Payment Utility, a new domestic and regional RTGS, an enhanced fast payment system on a pre-funded real-time model creating opportunities for non-banks and fintechs, alternative messaging networks, a QR+ interoperability standard and PEMKey credentials. SARB hosted its first 2026 PEM industry dialogue on 9-10 April 2026. PEM is the master programme reshaping SA payments infrastructure, with pre-funded fast payments, QR+ interoperability and non-bank participation defining the forward product roadmap.

Periodic update · new data 2026-09-22

Product Innovation & Market Development

The planned opening of the National Payment System to non-bank providers, via the targeted 2026 amendment to the National Payment System Act 78 of 1998, is expected to enable fintech-led e-money, acquiring and remittance products that integrate with PayShap and the Transactions Cleared on an Immediate Basis system, without requiring the provider to hold a full banking licence. This is a Probable finding, sourced from industry commentary framing the change against SARB's Vision 2025 payment-modernisation programme. This is a distinct, regulatory-access-driven development rather than a specific announced commercial product launch, and should be read as a structural market-opening signal for the fintech sector rather than a single company's product roadmap.

The timing of this market-access development, arriving in the same cycle as SARB's assumption of direct licensing authority from PASA, suggests the non-bank licensing pathway is being designed as part of the broader post-PASA regulatory architecture rather than as an isolated policy initiative.

Outlook

The marker to watch is the specific licence category, capital requirements and operational conditions attached to the activity-based non-bank licensing regime once the National Payment System Act amendment is finalised, since these details will determine how quickly fintech e-money, acquiring and remittance products can actually reach the South African market under the new pathway.

1 earlier distinct update(s)
Periodic update · new data 2026-08-26

Product Innovation & Market Development

PayShap, the instant payment scheme operated by BankservAfrica and PayInc, processed more than 100 million transactions in its first year of operation and has been rolled out in phases to Tier 1 and Tier 2 banks including Capitec and TymeBank, a dashboard item reflecting continued scaling rather than a new structural development. The scheme's per-transaction limit is reported inconsistently across sources: one source describes an increase from an initial R3,000 to R10,000, while another cites a R50,000 ceiling for peer-to-peer transfers; the interpreter's gaps register flags this as an unresolved discrepancy pending retrieval of a primary SARB or PayInc limit schedule, and the underlying finding carries only Low confidence as a result.

Separately, the Reserve Bank's National Payment System-opening initiative plans to allow PayShap integration into third-party wallets and applications, widening consumer access beyond direct bank-channel usage, and to open fintech access to regional payment schemes, part of the same Vision 2030+ strategic agenda referenced under the licensing module. Both the PayShap scaling and the NPS-opening initiative are Low-confidence findings sourced to Tier 4 secondary commentary rather than primary Reserve Bank publications, and should be read as indicative of direction rather than confirmed specifics.

Outlook

Reconciling the conflicting PayShap per-transaction limit figures against a primary SARB or PayInc source is the most immediate open item; until that is resolved, corridor-risk and consumer-usage modelling for South African instant payments should treat the higher R50,000 figure as unconfirmed. The pace and sequencing of NPS-opening implementation is worth tracking as a market-structure signal.

Sources and findings (5)
  1. T1https://www.resbank.co.za/en/home/what-we-do/payments-and-settlements/pem
  2. T2https://www.sanews.gov.za/south-africa/sarb-study-rules-out-launch-digital-currencyretrieved
  3. T3https://netcash.co.za/blog/top-digital-payment-trends-shaping-south-africa-in-2026/retrieved
  4. T3https://stitch.money/blog/open-banking-in-south-africa-payshap-capitec-pay-and-the-importance-of-bank-tppp-partnershipsretrieved
  5. T3https://news.bitcoin.com/south-african-reserve-bank-backs-payshap-over-digital-rand-as-cassim-targets-real-time-payments/retrieved

#

Consumer dispute resolution for payments runs through the National Financial Ombud Scheme (NFO), formed by amalgamating the Ombudsman for Banking Services, Credit Ombud and the long- and short-term insurance ombuds, and recognised by the Ombud Council; the FAIS Ombud handles financial-advice complaints. Notably, South Africa has NO mandatory APP-fraud reimbursement regime equivalent to the UK PSR scheme - authorised push-payment losses are generally treated as voluntary and borne by the consumer - even as instant rails accelerate. APP/social-engineering fraud is rising sharply (SA banks recorded ~98,000 digital fraud incidents and ~R1.9bn losses in 2024); industry is deploying tools such as a 'Scam Signal' and exploring consortium models, and a Confirmation-of-Payee-type capability is emerging but not yet universal.

Standing sub-brief · as of 23 June 2026272 words · last cycle 2026-06-23

Consumer Protection & APP Fraud

The defining consumer-protection feature this cycle is an absence: South Africa has no mandatory APP-fraud reimbursement regime equivalent to the UK PSR scheme. Authorised push-payment losses are generally treated as voluntary and borne by the consumer. This is confirmed via dedicated APP-fraud and ombud searches. APP and social-engineering fraud is rising sharply, with SA banks recording roughly 98,000 digital fraud incidents and about R1.9bn in losses in 2024. Industry is deploying tools such as Scam Signal and exploring consortium models, and with the UK and parts of the EU strengthening reimbursement, analysts expect the SA reimbursement debate to intensify. The absence of mandatory APP reimbursement is a material divergence from the UK and EU; rising scam volumes plus instant rails create growing policy pressure and consumer-liability exposure.

no periodic updates on record for this sub-brief

Sources and findings (4)
  1. T2https://www.nfosa.co.za/retrieved
  2. T3https://chadwicks.co.za/specialised-business/south-africas-next-big-scam-app-fraud/retrieved
  3. T3https://www.cnbcafrica.com/media/7778756845462/combating-south-africas-banking-fraud-problem-retrieved
  4. T3https://www.dailymaverick.co.za/article/2026-03-24-the-second-ordeal-what-happens-when-sa-fraud-victims-fight-back-1/retrieved

#

[Sentinel-fed payments-context position only; no original FIM analysis.] South Africa's AML/CFT regime is anchored on the Financial Intelligence Centre Act (FICA), strengthened by the General Laws (AML/CFT) Amendment Act 2022, administered by the FIC with sector supervisors (FSCA, PA and others). South Africa was grey-listed by FATF in February 2023 and removed on 24 October 2025 following reforms (beneficial-ownership transparency via the CIPC register, enhanced reporting under FIC Act ss.28-29, increased enforcement); the next full FATF mutual evaluation is expected to run 2026-2027. Grey-listing exit is expected to ease cross-border payment friction and correspondent-bank due diligence, but domestic obligations (RMCP, risk-based CDD/EDD, beneficial-ownership verification, STR reporting on goAML) remain fully in force.

Horizon · 2026-2027 (±multi_year)FATF full mutual evaluation of South Africaproposed · T3
Standing sub-brief · as of 23 June 2026233 words · last cycle 2026-06-23

AML/CFT & Financial Crime

This intelligence is sourced from the Sentinel.gi feed and carried as payments-context only; original illicit-finance analysis is routed to the Financial Intelligence Monitor. Per the Sentinel feed, on 24 October 2025 the FATF removed South Africa from its grey list, acknowledging significant AML/CFT improvements following reforms — beneficial-ownership transparency via the CIPC register, stricter FIC Act sections 28-29 reporting, improved enforcement and a successful July 2025 on-site review. South Africa had been grey-listed in February 2023 with eight identified deficiencies. The delisting is expected to ease cross-border payment friction and correspondent-bank due diligence, lowering de-risking pressure, compliance cost and transactional delay for SA cross-border payments. The next full FATF mutual evaluation is expected to run 2026-2027.

no periodic updates on record for this sub-brief

Sources and findings (4)
  1. T3https://www.mondaq.com/southafrica/money-laundering/1744668/south-africa-removed-from-financial-action-task-force-fatf-grey-listretrieved
  2. T?FIM (sentinel.gi) per-JID baseline profile — South Africa — South Africa's AML/CFT regime rests on the FIC Act, supervised by the FIC, Prudential Authority and FSCA, with crypto-asset service providers licensed as accountable institutions since 2022 and Travel Rule obligations live since April 2025. Following a February 2023 grey-listing over 22 action-plan items, FATF removed South Africa from increased monitoring in October 2025 after an on-site verification; EU and UK high-risk-third-country listings followed suit by December 2025.
  3. T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-003) — Gap: enforcement-absence
  4. T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-002) — Gap: regulatory-failure

#

Settlement access is bank-restricted: under the NPS Act only banks may participate in the domestic settlement system (SAMOS / Reserve Bank Settlement System), subject to PSMB authorisation, and the rand is also included in CLS. Regionally, SARB operates the SADC-RTGS for cross-border high-value settlement (ZAR-denominated). FATF grey-listing (Feb 2023 - Oct 2025) raised correspondent-bank enhanced due diligence and cross-border friction; delisting is expected to ease that pressure. Continental rails PAPSS and Buna currently restrict access to licensed banks, limiting non-bank correspondent access, while the activity-based reform and the PEM Programme aim to give non-banks direct clearing/settlement access via the National Payment Utility without bank sponsorship. SARB has also assisted other SADC central banks with cyber incidents, reflecting its regional settlement-operator role.

Movement — CHANGEDTPPP registration authority moved from PASA to SARB's National Payment System DepartmentCorresponding settlement/access registration authority change this cycle
Standing sub-brief · as of 23 June 2026260 words · last cycle 2026-10-18

Correspondent Banking, Settlement & Access

The analytical spine of this module is the bank versus non-bank access asymmetry. At the domestic settlement layer, only banks may participate in the settlement system, subject to Payment System Management Body authorisation and Reserve Bank Settlement System (SAMOS) requirements, with the rand also included in CLS. This bank-only settlement access blocks non-bank PSPs from direct settlement, forcing sponsor-bank dependency until NPU reform — a structural constraint the PEM and NPU reform targets.

Periodic update · new data 2026-10-18

Correspondent Banking, Settlement & Access

The structural reallocation of payment-system management authority in South Africa reaches directly into how third-party payment providers access registration and, by extension, participate in the settlement ecosystem. Third-party payment provider registration, previously administered by PASA, moved to SARB's National Payment System Department from 11 August 2026, the same effective date as the broader PSMB recognition withdrawal. This is a structural access-point change: the body a TPPP must register with, and ultimately the body whose criteria govern its continued eligibility to operate, has changed from an industry-run association to the central bank's own department.

For non-bank payment institutions specifically, this matters because TPPP registration has historically been a key access mechanism enabling non-bank entities to participate in payment processing without needing to hold a banking licence or rely entirely on sponsor-bank arrangements for every function. The transition does not, on the evidence available this cycle, change the underlying model of non-bank access to the payment system; existing TPPP registrations remain valid in the interim. What has changed is the administrative home of that registration function and, prospectively, the criteria that will govern it once SARB's draft Authorisation Framework for payment institutions is finalised.

The interim validity of existing registrations under legacy PASA criteria is a deliberate transitional accommodation, preventing immediate disruption to already-registered TPPPs while SARB builds out its own framework. This is a sensible continuity measure, but it does leave open, for an unspecified period, the question of what the new criteria will look like and whether currently-registered TPPPs will need to re-qualify or adapt their operations once the new framework takes effect. No confirmed finalisation date for the draft Authorisation Framework was available this cycle; the best available estimate places this in the 2027 first quarter, with meaningful uncertainty around that date.

The broader correspondent-banking and settlement-access significance of this transition is that it centralises a function previously distributed across an industry association back toward the central bank itself. Whether this changes the practical dynamics of sponsor-bank dependence, direct settlement access, or de-risking behaviour by banks toward non-bank TPPPs is not addressed by the evidence available this cycle, and should not be inferred from the administrative transition alone. What is established is the administrative fact of the transfer and its immediate effect on where registration now happens.

Outlook

The question of most direct relevance to correspondent-banking and settlement access is what SARB's eventual Authorisation Framework will require of TPPPs and other non-bank payment institutions once finalised, and whether it preserves, tightens, or loosens the access conditions that applied under PASA's legacy criteria. As scheduled, the framework's finalisation appears to fall within the 2027 first quarter, though this remains an estimate rather than a confirmed date, and the interim period will continue to see existing registrations operate under the superseded PASA-era criteria until SARB's own rules take their place.

4 earlier distinct update(s)
Periodic update · new data 2026-10-04

Correspondent Banking, Settlement & Access

Settlement and correspondent-access governance in South Africa's National Payment System sits structurally adjacent to the licensing consolidation now underway: with the South African Reserve Bank having concluded the withdrawal of the Payments Association of South Africa's payment system management body recognition effective 2 September 2026, the authorisation and registration functions governing participants in payment clearing-house and settlement arrangements now run directly through SARB's National Payment System Department rather than through PASA's prior industry-administered channels. No distinct correspondent-banking or settlement-access development separate from this licensing-administration shift was located this cycle, so this module's relevance this period is read through the W1a transition rather than through any freestanding settlement-infrastructure announcement.

The practical constraint for PSO, SO, and TPPP holders accessing clearing and settlement arrangements remains governed by the same licence categories as before the transition: these categories are unchanged, with only the administering body having moved from PASA to SARB. For participants whose settlement access depends on PCH authorisation or system-operator status, the relevant continuity point is that existing authorisations remain valid through the administrative transition, meaning access arrangements already in place are not disrupted by the change in which institution administers the underlying rulebook.

The structural read here is that centralising NPS rule-making and authorisation directly within SARB removes a layer of industry-body mediation that previously sat between individual settlement participants and the central bank on matters of system access. Whether this changes the practical experience of seeking or maintaining settlement access, for example in how quickly authorisation matters are resolved or how rulebook interpretation questions are handled, is not yet established on the evidence available this cycle, since the transition is administrative in form and the substantive licensing framework governing access has not itself changed.

Outlook

The module to watch going forward is whether SARB's direct administration of authorisation functions produces any divergence in how correspondent-access and settlement-participation matters are handled compared with the PASA-administered arrangement. Because the underlying licence categories, and therefore the substantive access criteria, are unchanged, any near-term effect is more likely to be procedural than structural: a change in which institution a firm engages with on settlement-access questions, rather than a change in what is required to obtain or retain that access. No distinct correspondent-banking development beyond the PASA-SARB transition itself was identified this cycle, and this module's content should be read as a downstream implication of the W1a licensing-administration shift rather than as an independent finding.

Periodic update · new data 2026-09-29

Correspondent Banking, Settlement & Access

The analytical spine of this module is the asymmetry between bank and non-bank access to correspondent and settlement infrastructure, and South Africa's Common Monetary Area developments this cycle bear directly on that asymmetry at a regional level. Balance-of-payments purpose codes have been aligned across the CMA, comprising South Africa, Namibia, Lesotho and Eswatini, resolving a prior source of code-mismatch payment failures between CMA member banks as of August 2026. Separately, CMA banks are required to migrate low-value cross-border payments from the SADC RTGS system to TCIB, the region's real-time low-value cross-border payment scheme, by March 2027. This routing change occurs behind the scenes from an end-client perspective, meaning the settlement rail underlying CMA cross-border low-value payments will shift without a visible change to the client-facing payment experience. Together, the purpose-code harmonisation and the mandated TCIB migration represent a deliberate regional push toward unified real-time low-value cross-border payment infrastructure across the four CMA member states, addressing a structural settlement-access issue that had previously produced payment failures due to code mismatches between national systems.

Outlook

The March 2027 deadline for CMA banks to complete migration to TCIB is the concrete date to watch. Whether the harmonised purpose codes and the TCIB migration together eliminate the prior pattern of cross-border payment failures within the CMA, once the migration is complete, will be the practical test of whether this settlement-infrastructure push achieves its stated aim.

Periodic update · new data 2026-09-22

Correspondent Banking, Settlement & Access

The defining development for settlement and access this cycle is SARB's direct absorption of payment-institution licensing, authorisation and registration functions formerly delegated to the Payments Association of South Africa, alongside settlement-system oversight itself. This is a Confirmed, Tier-1 finding sourced directly from SARB's own payments-and-settlements publication. The bank-versus-non-bank access asymmetry that has historically defined South African payment-system participation is the analytical spine of this shift: PASA's self-regulatory model was bank-led, and its replacement by direct SARB oversight, combined with the parallel move toward activity-based non-bank licensing, signals a structural change in how non-bank entities may eventually gain settlement-system access relative to banks.

SARB has directly confirmed that everyday payment services, including card, EFT, debit order and ATM transactions, are unaffected by the PASA transition, a Confirmed finding sourced from SARB's own official statement. This confirmation addresses the immediate operational-continuity question the governance change raises, even as the longer-term question of how non-bank access to settlement infrastructure will evolve under direct SARB oversight remains open.

Outlook

The key marker for the next cycle is whether SARB's direct assumption of licensing and settlement-oversight functions produces any near-term change in practical access conditions for non-bank payment institutions, or whether the immediate effect is limited to a governance-body substitution with substantive access conditions unchanged pending the separate National Payment System Act amendment process.

Periodic update · new data 2026-08-26

Correspondent Banking, Settlement & Access

South Africa's Reserve Bank is pursuing regional settlement integration as a structural priority under its Vision 2030+ agenda, targeting the SADC Transactions Cleared on an Immediate Basis scheme, a real-time multi-currency cross-border payment system, and monitoring engagement with the Pan-African Payment and Settlement System, with the stated aims of reducing remittance costs and harmonising messaging standards around ISO 20022. This is an Elevated-impact, Low-confidence finding sourced to Werksmans Attorneys commentary rather than a primary Reserve Bank publication, and the interpreter's gaps register separately notes that PAPSS-specific South African integration status has not been confirmed beyond the Vision 2030+ framing itself.

The correspondent-banking analytical spine for this module is the structural asymmetry between bank and non-bank access to cross-border settlement rails; South Africa's SADC TCIB and PAPSS ambitions are, at this stage, framed at the level of strategic intent within a Reserve Bank consultation paper rather than as concrete integration milestones with dates or technical specifications attached. The interpreter's own under-indexing note flags that emerging-market and regional-rail coverage, including SADC TCIB and PAPSS specifically, is under-represented in this cycle's sourcing relative to Anglosphere and EU regulatory content, a gap that should inform how much weight is placed on the current Low-confidence characterisation.

Outlook

Watch for a primary Reserve Bank publication or SADC Payment System Oversight Committee document that would move the TCIB and PAPSS integration ambitions from strategic framing to confirmed technical milestones. Given the acknowledged under-indexing of regional-rail coverage this cycle, targeted sourcing effort on SADC and PAPSS primary documentation would materially improve confidence going into the next cycle.

Sources and findings (4)
  1. T1https://www.resbank.co.za/en/home/what-we-do/payments-and-settlementsretrieved
  2. T1https://www.resbank.co.za/en/home/what-we-do/payments-and-settlements/pem
  3. T3https://www.masthead.co.za/newsletter/south-africas-fatf-greylist-exit-what-it-means-for-accountable-institutions-and-fsps/retrieved
  4. T1https://www.resbank.co.za/content/dam/sarb/what-we-do/payments-and-settlements/cross-border-payments-conference/documents/paper-cost-patterns-remittance.pdfretrieved

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Trailing-12-month commercial activity (run date 2026-06-23) shows strong consolidation and a funding rebound: South African startups raised ~$335.9m across 42 deals in 2025 (a 234% surge on 2024), with fintech leading M&A (67 deals, up 72% YoY). Key payments events: SARB's 50% PayInc stake (Nov 2025); Nedbank's acquisition of iKhokha and Lesaka's acquisitions of Adumo and Bank Zero; Stitch's $55m Series B (April 2025, led by QED) plus acquisitions of Exipay/ExiPay (Jan 2025) and Efficacy Payments (an SARB-designated DCSP); Yoco's first acquisition (AI startup Dyner.AI, June 2026) and appointment of a new CEO (May 2026); Lula's R340m ($21m) raise from FMO (Feb 2026); and crypto-payments integrations (Absa/Ripple, Ozow/MoneyBadger, Binance Pay at 650,000+ merchants).

Standing sub-brief · as of 23 June 2026368 words · last cycle 2026-10-18

Commercial Intelligence

The commercial cycle is running ahead of the regulatory one. In 2025, South African startups raised a combined $335.9 million across 42 deals, a 234% surge from $100.4m in 2024, at an average deal size of roughly $7.99m, while fintech M&A increased 72% year-on-year with 67 deals. This signals a strong capital and consolidation cycle in SA fintech and payments.

Periodic update · new data 2026-10-18

Commercial Intelligence & Fintech

Nuvei announced the expansion of its local-acquiring footprint to South Africa, its 52nd market globally, around 15 October 2026. The announcement positions South Africa as a continued point of geographic expansion for Nuvei's acquiring business, but the announcement itself carries a notable ambiguity: it references PASA terminology and processes in describing the basis for its South African authorisation, despite the fact that licensing, authorisation and registration functions for payment institutions had already moved to SARB with effect from 11 August 2026, well before the announcement date. No transaction value or deal terms apply here, as this is a market-entry announcement rather than a capital transaction; the event is an expansion of acquiring footprint rather than an M&A or funding development.

The commercial significance of this announcement lies less in Nuvei's specific market entry, which is a routine footprint-expansion move for a payments company of its scale, and more in what the announcement's own imprecision reveals about the state of the regulatory transition in South Africa. A sophisticated international payments company publicly referencing an authorisation body and process that had already been superseded by the time of its announcement suggests that the PASA-to-SARB handover has not yet been uniformly or clearly communicated across the market, or that some transitional overlap in process genuinely persists even after the formal recognition withdrawal took effect. Neither the precise authorising body for Nuvei's South African authorisation, nor a confirmed approval date or reference number, was available in the source material reviewed this cycle.

From a commercial-intelligence perspective, this episode is a useful marker of market conditions during a regulatory transition period: new entrants and expanding players are proceeding with market-entry announcements even as the underlying authorisation architecture is mid-transition, which creates a degree of informational noise around exactly which rules and which authority governs newly announced entries. This is itself commercially relevant intelligence for other payment companies considering South African market entry during this window, independent of the specific facts of Nuvei's own authorisation status.

Outlook

Whether Nuvei's South African authorisation is subsequently clarified as having been granted under legacy PASA-administered criteria (consistent with the transitional validity of existing registrations) or under SARB's new administrative process will be a useful marker of how the market is actually experiencing the PASA-SARB handover in practice, as distinct from how the transition has been formally described by the regulator. Other payment companies evaluating South African market entry during this transitional window should expect some continued ambiguity in public communications about authorisation pathways until SARB's own Authorisation Framework is finalised and market practice settles around it.

1 earlier distinct update(s)
Periodic update · new data 2026-10-11

Commercial Intelligence & Fintech

Luno (Pty) Ltd acquired cross-border payments firm GTXN in September 2026, with the deal amount not publicly disclosed. The acquisition continues Luno's build-out of business-to-business and institutional cross-border payment services, extending its activity beyond its established retail crypto-exchange business into cross-border payments infrastructure directly.

In the same month, Luno launched instant stablecoin minting for corporate clients in partnership with Meridian, a US-regulated clearinghouse. This product targets institutional and corporate clients seeking stablecoin liquidity rather than domestic retail payment use, positioning Luno in the business-to-business stablecoin infrastructure space at a moment when the domestic payments-law classification of stablecoins as non-money remains in tension with the Mangundhla exchange-control finding.

Separately, VALR's co-founder and chief executive, Farzam Ehsani, stated that at least R2.2 billion in potential foreign investment in South African crypto businesses has been placed on hold, including a reported R1.6 billion private-equity investment, attributing the hold to regulatory uncertainty over the draft cross-border capital-flow rules. This figure is a party's own public statement and has not been independently verified or audited, so it should be treated as an industry-reported signal of investor caution rather than a confirmed market measurement.

Outlook

Luno's dual move into cross-border payments infrastructure and business-to-business stablecoin minting positions it to capture institutional demand regardless of how the domestic retail stablecoin classification question resolves, since both the GTXN acquisition and the Meridian partnership target corporate rather than retail flows. Whether the R2.2 billion in reportedly paused foreign investment materialises once the Capital Flow Management Regulations consultation outcome is known, closed since 30 September 2026, remains to be seen, and will be a useful indicator of whether regulatory clarity, once achieved, restores investor confidence in the sector.

Sources and findings (6)
  1. T3https://www.finasa.org.za/post/south-african-fintech-ecosystem-30-day-summary-feb-march-2026-funding-regulation-key-dealsretrieved
  2. T3https://lucidityinsights.com/news/stitch-secures-55mretrieved
  3. T3https://techpoint.africa/insight/techpoint-digest-1371/retrieved
  4. T3https://en.wikipedia.org/wiki/Yocoretrieved
  5. T3https://www.finasa.org.za/post/south-african-fintech-ecosystem-30-day-summary-feb-march-2026-funding-regulation-key-dealsretrieved
  6. T3https://techcabal.com/2026/02/06/south-africa-digital-payments/retrieved
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