Draft Directive in respect of specific payment activities within the National Payment System (Activity-Based Authorisation)

On 3 March 2025 the South African Reserve Bank (SARB) published, for consultation, a draft 'Directive in respect of specific payment activities within the national payment system' together with a draft exemption notice. The draft is a key step in the SARB's payments-modernisation and activity-based authorisation reform, which aims to move South Africa away from a system in which direct participation in clearing and settlement is effectively limited to banks, towards a framework that authorises bank and non-bank participants according to the specific payment activities they perform. This is potentially transformative for fintechs that have historically had to access the national payment system through a sponsoring bank. The draft classifies payment activities functionally, for example the issuing of electronic money and payment instruments, the acquiring of payment instructions, clearing and settlement, payment initiation, third-party payments, scheme management and money remittance, and prescribes reporting requirements for persons (both banks and non-banks) who conduct or seek to conduct those activities. The accompanying draft exemption notice would provide transitional relief while the broader authorisation framework and the reform of the National Payment System Act are finalised. As a draft instrument in consultation at the time of drafting, it does not yet impose binding obligations and its final form and effective date are not settled; it is recorded here to capture the live direction of South African payments regulation. If finalised, it would materially widen non-bank and fintech access to the national payment system and reshape the licensing perimeter for payment activities.

1. 1Part of SARB's activity-based authorisation reform of the national payment system
2. 2Functional classification of payment activities (e-money issuing, acquiring, clearing/settlement, payment initiation, third-party payments, scheme management, remittance)
3. 3Reporting requirements for banks and non-banks conducting specified payment activities
4. 4Accompanying draft exemption notice providing transitional relief
5. 5Aims to widen non-bank/fintech access to the NPS beyond the bank-sponsored model
6. 6Draft/consultation status at time of drafting; final form and effective date not yet settled