Nikolai Timofejev
15 years in FinTech and payments. Maps your business model to the right licence scope and leads the file all the way to the authorisation or the registration, including banking and payment rails.
Get a payment license in South Africa.
South Africa does not let a non-bank issue e-money. Position Paper NPS 01/2009, published by the Reserve Bank's National Payment System Department in November 2009, has never been withdrawn, and paragraph 7 of it says that 'only South African registered banks may issue e-money'; the same paragraph points a non-bank at section 52 of the Banks Act, which means an arrangement with a bank that issues in its own name. What a non-bank holds itself is one of two things: authorisation to act as a system operator under section 4(2)(c) of the National Payment System Act 78 of 1998, or registration as a third-party payment provider under Directive No. 1 of 2007. Neither carries a capital figure, because none is prescribed. The money requirement lives in exchange control instead, where an Authorised Dealer with Limited Authority holds R2 million to R8 million of unimpaired capital by category.
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South Africa in brief
Banks issue the e-money. The licence a non-bank can hold prints no capital figure at all.
Start with the answer that rewrites most business plans. Position Paper NPS 01/2009, issued by the Reserve Bank's National Payment System Department in November 2009, is still on the central bank's list of current position papers and still says at paragraph 7: 'only South African registered banks may issue e-money.' Nothing has replaced it. The same paragraph names the way round it - 'Section 52 of the Banks Act allows for non-banks to enter into arrangements with banks that may allow them to offer payment-related services in conjunction with the bank' - so a non-bank issues stored value through a sponsoring bank, or it becomes a bank. What it can hold in its own name comes from the National Payment System Act 78 of 1998, in force since 28 October 1998 and still the operative Act, amended by Acts 22 of 2004, 34 of 2005, 40 of 2007, 22 of 2008, 19 of 2012 and 45 of 2013. Section 4(2)(c) covers authorisation to act as a system operator. Directive No. 1 of 2007, gazetted at Government Gazette 30261 of 6 September 2007, covers registration as a third-party payment provider. Neither prescribes capital. Section 6(1) keeps clearing away from a non-bank unless the central bank designates it by Gazette notice under section 6(3)(a), and settlement stays closed to non-banks outright.
Two things are moving underneath the page. The exemption notice that would let a non-bank issue e-money in its own name is a draft under section 1(1), paragraph (cc) of the Banks Act 94 of 1990, and the activity-based directive that would authorise the activity is a draft under section 12(1) of the NPS Act, dated May 2026 and marked 'Draft for consultation' after earlier versions of 3 March 2025 and 14 November 2025. The March 2025 table proposed initial capital of R5,000,000 for issuing e-money, R3,000,000 for third-party payments and R6,000,000 each for clearing and settlement, with own funds at the higher of that figure or 10% of the previous year's fixed expenses. None of it is law yet. And the body that has been taking these applications is being taken apart: the central bank is withdrawing its recognition of the Payments Association of South Africa as payment system management body, phase one on 11 August 2026 and phase two on 2 September 2026, with functions going to the Reserve Bank and to PayInc. Then exchange control, the second licence nobody budgets for. Regulation 2(1) of the 1961 Regulations reserves dealing in foreign currency to Authorised Dealers, and an Authorised Dealer with Limited Authority carries R2 million to R8 million of unimpaired capital by category. Corporate tax is 27%, VAT 15%. We run the file from Dubai.
Position Paper NPS 01/2009 has never been withdrawn: 'only South African registered banks may issue e-money'. A non-bank issues through a sponsoring bank under section 52 of the Banks Act. In its own name it holds a system-operator authorisation under section 4(2)(c) of the National Payment System Act 78 of 1998, or a third-party payment provider registration under Directive No. 1 of 2007.
Neither prescribes capital. The approved criteria ask only for adequate insurance. Exchange control is where the money sits: an ADLA holds R2 million to R8 million of unimpaired capital. No statutory decision period exists, and 21 working days is the published standard. Tax 27%, VAT 15%. We run the file from Dubai.
The routes
System operator, third-party payment provider - and a bank behind any stored value.
A non-bank holds one of two things here. A system operator processes payment instructions for other people and never lets the funds through its own account; a third-party payment provider does the opposite, and is registered by its bank rather than authorised on application. Stored value sits outside both, because a registered bank issues it and the fintech attaches to that bank under section 52 of the Banks Act.
System operator or third-party payment provider - and a bank behind any stored value.
01 - SYSTEM OPERATOR
Authorised to process on behalf of participants
Authorisation under section 4(2)(c) of the National Payment System Act 78 of 1998, on the criteria the Reserve Bank approved, to provide services to two or more persons in respect of payment instructions. Directive No. 2 of 2007 draws the boundary at clause 3.1.4: the operator follows only the instructions of the person it serves, and must 'not pay such funds from or transfer such funds to its own account'.
Authorisation under section 4(2)(c) of the National Payment System Act 78 of 1998, on the criteria the Reserve Bank approved, to provide services to two or more persons in respect of payment instructions. Directive No. 2 of 2007 draws the boundary at clause 3.1.4: the operator follows only the instructions of the person it serves, and must 'not pay such funds from or transfer such funds to its own account'.
- ✓Services to two or more persons in respect of payment instructions
- ✓No capital, own-funds, net-asset or guarantee figure anywhere
- ✓Adequate insurance against claims by clients or beneficiaries (cl. 3.3.4)
- ✓Compulsory above 10,000 transactions or R10 million a month (cl. 3.1(e))
- ✓R10,000 application · R2,000 a payment system · R2,000 a year, excl. VAT
- ✓Auditors' report, business continuity and disaster recovery plans
02 - THIRD-PARTY PAYMENT PROVIDER
Over 300 on the August 2024 registerRegistered to collect from or pay to third persons
Directive No. 1 of 2007, Government Gazette 30261 of 6 September 2007, covers the beneficiary service provider that accepts money from multiple payers for one beneficiary and the payer service provider that pays multiple beneficiaries for one payer. The route runs through the bank: you inform your banker, the bank registers you with the payment system management body, and that body supplies the records to the central bank on request.
Third-party payment provider: registered by your bank under Directive No. 1 of 2007, no capital, no fee, 21 working days.
- ✓Beneficiary service provider (cl. 2.1) or payer service provider (cl. 2.2)
- ✓Registered by your sponsoring bank, not by direct application
- ✓No capital requirement, and no trust account required by the directive
- ✓No registration fee is charged
- ✓21 working days from a complete file, as a published standard
- ✓Contravention is an offence (cl. 4.2) · R1 million or five years (s. 14)
Costs and timelines are confirmed for your case before any work begins. Two things sit outside these cards on purpose. E-money is issued by a registered bank with the fintech attached under a section 52 Banks Act arrangement, so it is not a licence you hold; and clearing, if your model needs it, requires designation as a clearing system participant by notice in the Gazette under section 6(3)(a), with settlement sponsored by a member of the payment system management body. Non-banks cannot settle at all. Three figures nobody publishes: the fee for that designation, the fee for an Authorised Dealer with Limited Authority, and how many ADLAs exist. We obtain each for your case.
Why South Africa
A market of 63.52 million where the payments licence asks for no capital.
Statistics South Africa put the mid-year population at 63.52 million in its release of 30 July 2026. The deposit insurance corporation lists 34 member banks, 14 of them commercial and 12 local branches of foreign banks, which is the pool a sponsoring bank comes from. What the licence itself asks for is set out below.
✓
No capital figure to raise
Nothing prescribes a minimum capital, own funds, net assets or guarantee for a system operator, a third-party payment provider or a designated clearing system participant. The approved criteria ask only that the operator be adequately insured against claims by clients and beneficiaries.No own-funds or guarantee figure prescribed.
✓
A foreign company is eligible on its face
Clause 3.3.1 of the approved criteria takes a company registered under the Companies Act 1973, a close corporation, or one registered under 'any relevant international legislation'. No local-office or director-residency rule appears in that document.Eligible on the face of criteria 3.3.1.
✓
PayShap and SAMOS
The instant rail launched on 13 March 2023 and had carried about 251 million transactions, with a settlement value of R198.5 billion and 4.6 million registered ShapIDs, as at March 2025. Settlement runs on SAMOS, which handled R153.7 trillion over 16.0 million transactions in 2024.Instant rail since March 2023.
✓
A route more than 300 firms already use
The public register of third-party payment providers dated 14 August 2024 lists in excess of 300 of them, sorted by sponsoring bank and by service. Registration itself is free. There is no equivalent register of authorised system operators, and no count of them is published anywhere.Public register of 14 August 2024.
✓
Twenty-one working days, published
The administrative standard for both system-operator authorisation and third-party-payment-provider registration is 21 working days after all the required information arrives. No statute prints a clock, so that standard is the only date to plan against.The only published standard.
✓
The next regime is already on the table
Three drafts of the activity-based framework are public: 3 March 2025, 14 November 2025 and May 2026. National Treasury meant to table a replacement Bill during 2025 and no Act has followed, so a business built now is sized against the capital table the March 2025 draft printed.Three public drafts, none in force.
How it compares
How South Africa differs from the other African routes.
Nigeria, Kenya and Mauritius all license a non-bank to issue e-money. South Africa does not, and it asks no capital for either of the two things a non-bank can hold. The honest comparison is below.
South Africa vs other jurisdictions
| Feature |  South Africa | Other jurisdictions |
|---|---|---|
| E-money by a non-bank | Not permitted · bank sponsorship only | Licensed in Nigeria, Kenya and Mauritius |
| Capital | None prescribed · ADLA R2m-R8m | NGN 2bn Nigeria · KES 20M Kenya · Rs 5M Mauritius |
| Decision clock | None · 21 working days published | 60 working days Mauritius · none in Kenya |
| Corporate tax | 27% · VAT 15% | 30% Nigeria · 30% Kenya · 15% Mauritius |
E-money by a non-bank
South AfricaNot permitted · bank sponsorship only
Other jurisdictionsLicensed in Nigeria, Kenya and Mauritius
Capital
South AfricaNone prescribed · ADLA R2m-R8m
Other jurisdictionsNGN 2bn Nigeria · KES 20M Kenya · Rs 5M Mauritius
Decision clock
South AfricaNone · 21 working days published
Other jurisdictions60 working days Mauritius · none in Kenya
Corporate tax
South Africa27% · VAT 15%
Other jurisdictions30% Nigeria · 30% Kenya · 15% Mauritius
Country by country
| Country | License type | Taxation | Requirements |
|---|---|---|---|
| South Africa | System operator · TPPP (SARB) | 27% · VAT 15% | No capital prescribed · no clock |
 Nigeria | MMO · PSSP (CBN) | 30% large companies | NGN 2bn MMO · settlement account at a bank |
 Kenya | PSP · e-money issuer (CBK) | 30% · VAT 16% | KES 5M / 20M · no statutory clock |
 Mauritius | PSP · e-money issuer (BoM) | 15% · VAT 15% | Rs 3M / 5M · 60 working days |
South AfricaLicense typeSystem operator · TPPP (SARB)
Taxation27% · VAT 15%
RequirementsNo capital prescribed · no clock
NigeriaLicense typeMMO · PSSP (CBN)
Taxation30% large companies
RequirementsNGN 2bn MMO · settlement account at a bank
KenyaLicense typePSP · e-money issuer (CBK)
Taxation30% · VAT 16%
RequirementsKES 5M / 20M · no statutory clock
MauritiusLicense typePSP · e-money issuer (BoM)
Taxation15% · VAT 15%
RequirementsRs 3M / 5M · 60 working days
Before you apply
Requirements for the South African routes.Requirements for the SARB routes.
The Act sets the categories, the 2007 directives set the conduct, and the criteria the Reserve Bank approved set what an application contains. The list below is what a passing file looks like, including the parts the instruments leave blank.
01
An applicant the approved criteria will accept: clause 3.3.1 takes a company registered under the Companies Act 1973, a close corporation under the Close Corporations Act 1984, or a company registered under 'any relevant international legislation', so a foreign-incorporated applicant is eligible on the face of the document; South African incorporation runs through the CIPC under the Companies Act 71 of 2008, and no director-residency, local-office or fit-and-proper rule is specified for system operators or third-party payment providers in the current instruments.
02
No capital to raise, and no pretending otherwise: neither 2007 directive nor the approved criteria prescribes a minimum capital, own-funds, net-asset or guarantee figure, and the only financial obligation printed is clause 3.3.4, that the operator 'be adequately insured against claims by clients and/or beneficiaries', with no minimum sum insured stated anywhere.
03
A sponsoring bank engaged before anything else, because the bank registers a third-party payment provider with the payment system management body under clauses 3.1.6 and 3.2, sponsors a designated clearing system participant in settlement, and is the only lawful issuer of e-money under a section 52 Banks Act arrangement.
04
A flow of funds designed to clause 3.1.4 of Directive No. 2 of 2007 if you take the system-operator route: the operator follows only the instructions of the person it serves and must 'not pay such funds from or transfer such funds to its own account', so a model that sweeps client money through the operator's own account is a third-party payment provider model instead.
05
The system-operator application pack: the external auditors' report for the latest financial year end, a documented business continuity plan and a disaster recovery plan, PCI DSS certification or an Attestation of Compliance from a Qualified Security Assessor where card services are provided, Visa and Mastercard registration where applicable, and the two largest active clients named with their company registration numbers.
06
Client-money handling agreed with the bank rather than read off a statute: no trust or segregated account is required of a system operator or a third-party payment provider under the current instruments, so segregation is imposed contractually by the sponsoring bank, and the draft framework that would make a trust account mandatory has not been gazetted.
07
A FICA position taken early, because it is the classic late discovery: the Financial Intelligence Centre Act 38 of 2001 lists accountable institutions in Schedule 1, and the item that catches payments is Item 19, a person carrying on the business of a money or value transfer provider - there is no Schedule 1 item for a payment service provider or an e-money issuer as such. Registration under section 43B is free on the goAML portal within 90 days of the business starting operations, failure to register carries a fine of up to R10 million, and section 42 requires a risk management and compliance programme.
08
An exchange-control route settled before the first cross-border payment: regulation 2(1) of the Exchange Control Regulations 1961 reserves buying and selling foreign currency to Authorised Dealers, with regulation 22 backing it at R250,000 or five years, so either every foreign-currency leg goes through a bank or you apply to the Financial Surveillance Department for your own limited authority on R2 million, R3 million, R5 million or R8 million of unimpaired capital by category; separately, Directive No. 1 of 2025, Government Gazette 52435 of 1 April 2025, moves Common Monetary Area low-value cross-border EFT of R5 million or less off SADC-RTGS, closing that route on 31 March 2027 and requiring TCIB from 1 April 2027.
09
Cybersecurity and data work that is already binding: Directive No. 1 of 2024 on cybersecurity and cyber-resilience within the national payment system applies to participants now, and the Protection of Personal Information Act 4 of 2013 requires an Information Officer registered with the Information Regulator under section 55(2), governs personal information leaving the country under section 72, and carries a fine of up to R10 million for a failure to notify.
10
B-BBEE and tax registrations: the Amended Financial Sector Code, Government Gazette 41287 of 1 December 2017, binds any person conducting a business, trade or profession in the South African financial sector, treating annual total revenue up to R10 million as an Exempted Micro Enterprise and R10 million to R50 million as a Qualifying Small Financial Institution, with a full scorecard and a verified certificate above that; banks and corporate customers ask for the certificate long before any regulator does. Corporate income tax runs at 27% and VAT registration is compulsory at R2.3 million of taxable supplies.
01
Company under criteria 3.3.1; foreign form accepted.
02
No capital; adequate insurance only (cl. 3.3.4).
03
A sponsoring bank, engaged before anything else.
04
Funds never through the operator's account (cl. 3.1.4).
05
Auditors' report, BCP and DRP, PCI DSS for cards.
06
Segregation by bank contract, not by statute.
07
FICA: Item 19, goAML within 90 days, free.
08
Exchange control: Authorised Dealer or ADLA.
09
Directive 1 of 2024 cyber; POPIA officer registered.
10
B-BBEE certificate; CIT 27%, VAT from R2.3m.
Reflects the National Payment System Act 78 of 1998 as amended to 2013, Directives 1 and 2 of 2007, Directive 1 of 2024, Directive 1 of 2025, Position Paper NPS 01/2009 and the system-operator criteria the Reserve Bank approved, as of 2026. Clearing without being an eligible participant under section 6(2), denying or preferring access under section 6A(5) and ignoring a directive under section 12(8) are offences, and section 14 prices each of them at a fine of up to R1 million, five years in prison, or both. No official page states which body receives system-operator authorisation and third-party-payment-provider registration applications after 2 September 2026, so we confirm the addressee before your file is lodged.NPS Act 78 of 1998; Directives 1 and 2 of 2007; Directive 1 of 2024; Directive 1 of 2025; PP NPS 01/2009, as of 2026.
How it works
From first call to a live authorisation.
01
Route and strategy
System operator, third-party payment provider, both, or stored value issued by a sponsoring bank under section 52 of the Banks Act; and whether an ADLA authorisation is needed at all.System operator, TPPP, bank sponsorship, ADLA.
02
Entity and bank
The South African company incorporated through the CIPC, or the foreign entity kept where clause 3.3.1 covers it, and the sponsoring bank engaged early because it does the registering.CIPC company; sponsoring bank engaged early.
03
The file
The approved-criteria pack for a system operator, or the bank's registration pack for a third-party payment provider, with the FICA compliance programme and the Directive 1 of 2024 cyber documentation built alongside.Criteria pack, FICA programme, cyber documents.
04
Filing and review
Twenty-one working days from a complete file is the only published standard, and nothing in the Act sets a deadline. The addressee is confirmed first, because payment system management functions moved to the Reserve Bank and PayInc on 11 August and 2 September 2026.21 working days; addressee confirmed first.
05
Live
Registration with the Financial Intelligence Centre on goAML inside 90 days of starting operations, the POPIA Information Officer registered, the exchange-control route running and reporting to the bank and the central bank started.goAML in 90 days, POPIA officer, reporting on.
Quick facts
RegulatorSouth African Reserve Bank (NPSD)
Exchange controlSARB Financial Surveillance Department
LawNPS Act 78 of 1998, as amended to 2013
RoutesSystem operator · third-party payment provider
CapitalNone prescribed · ADLA R2m-R8m
FeesR10,000 + R2,000 a system · TPPP free
DecisionNo statutory period · 21 working days published
Timeline6-12 months realistic
Nothing in the National Payment System Act, in either 2007 directive or in any of the three draft frameworks sets a decision period. The only published standard is 21 working days from a complete file, which puts the timetable on two things: how finished the pack is, and how quickly a bank agrees to sponsor you.
Your South Africa desk
Run from our Southern Africa desk.
Prifinance - Southern Africa desk
Dubai · coordinating South African mandates
33 Level, Al Saqr Business Tower, Dubai
01
The applicant entity
Incorporation through the CIPC under the Companies Act 71 of 2008, or the foreign-company route clause 3.3.1 of the approved criteria leaves open, with the shareholding documented to the beneficial owner before the file is lodged.CIPC company, or the foreign form 3.3.1 allows.
02
The application file
The system-operator pack built to the approved criteria - auditors' report, business continuity and disaster recovery plans, PCI DSS evidence where cards are involved - or the third-party-payment-provider pack your sponsoring bank submits for you.Criteria pack, or the bank's TPPP pack.
03
The sponsoring bank
The relationship that gates all three routes: registration of a third-party payment provider, settlement sponsorship for a designated clearing system participant, and any e-money issued under a section 52 Banks Act arrangement.It gates registration, settlement and e-money.
04
Exchange control
Every foreign-currency leg either routed through an Authorised Dealer or brought inside your own ADLA authorisation from the Financial Surveillance Department, with the R2 million to R8 million of unimpaired capital and the fit-and-proper testing that comes with it.Authorised Dealer, or your own ADLA.
We also have offices in
Tallinn
Estonia
Roseni 13
Vilnius
Lithuania
Gedimino pr. 2
Prague
Czech Republic
Vlkova 532/8, Žižkov
London
United Kingdom
7 Bell Yard
Madeira
Portugal
Rua da Alegria 31, 1F
Budapest
Hungary
Korányi Sándor u. 4
Istanbul
Turkey
Perpa Ticaret Merkezi, A Blok
Good to know
Taxation of payment companies in South Africa.
A 27% corporate rate, VAT at 15% with registration compulsory from R2.3 million of taxable supplies, and dividends taxed at 20% whether the shareholder is resident or not. There is no financial transactions tax.
Corporate income tax 27%
The rate for years of assessment ending between 1 April 2026 and 31 March 2027, per the SARS Budget 2026 Tax Guide. It applies to a payment company the same way it applies to anyone else.Years ending to 31 March 2027.
The small business ladder
A Small Business Corporation pays nothing on the first R99,000, then 7% up to R365,000, 21% up to R550,000 and 27% above it. Whether a payments start-up qualifies turns on its shareholding and its other interests.0% / 7% / 21% / 27% ladder.
VAT 15%
Registration becomes compulsory at R2.3 million of taxable supplies a year. Financial services are largely exempt supplies here while fee-based payment services are generally standard-rated, so the product is mapped line by line before pricing is set.Registration compulsory at R2.3 million.
Dividends tax 20%
Twenty per cent on distributions, and the same 20% on a payment to a non-resident as a final tax, subject to treaty relief. The treaty position is worked out before the holding structure is fixed, not after.Same rate to non-residents, final.
Interest and royalties abroad
Fifteen per cent withholding on interest paid to a non-resident and 15% on royalties. Intra-group funding and licence fees are priced with those rates in the model.15% each to non-residents.
No transactions tax, and no payments levy
South Africa levies no financial transactions tax. Supervisory levies under the Financial Sector and Deposit Insurance Levies Act 11 of 2022 fall on supervised financial institutions, and neither a system operator nor a third-party payment provider is one.And no levy on payment participants.
Tax summary
Corporate income tax27%
Small business corporation0% / 7% / 21% / 27%
VAT15% · registration at R2.3 million
Dividends tax20% · 20% to non-residents, final
Interest and royalties abroad15% each
Financial transactions taxNone
*Figures as of 2026, from the SARS Budget 2026 Tax Guide covering 1 March 2026 to 28 February 2027. No supervisory levy figure is published for system operators or third-party payment providers, because neither is a supervised financial institution under the Financial Sector and Deposit Insurance Levies Act 11 of 2022. Treaty and regime positions are assessed per structure.
Turnkey professional support
Experienced lawyers and international consultants.
We provide end-to-end support, from company registration and the application file to regulatory interaction and compliance oversight - with an individualized approach to each client.
Oleksii Kindratenko
Builds the application itself: South African company, AML/KYC policy pack, capital structure and tax registrations. His document sets are the reason reviews finish in months, not years.
Eugeniu Bevziuc
First point of contact for international founders. Runs the whole setup remotely, across time zones and languages - from the first call to a live, authorised operator.
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South Africa · SARB
Launch your payment project in South Africa with expert support.
Full-service assistance - from company formation to system-operator authorisation, TPPP registration, the sponsoring bank, exchange control and ongoing compliance.
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Our legal team will analyze your case at no cost and provide a written legal opinion: which jurisdiction, licence scope, or route fits your business.
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Request a free conclusion →FAQ
The South African payment licence, answered.
Can a foreign fintech issue e-money in South Africa?+
No, not in its own name. Position Paper NPS 01/2009 says at paragraph 7 that 'only South African registered banks may issue e-money', and the central bank has never withdrawn or replaced it. The same paragraph gives the alternative: section 52 of the Banks Act lets a non-bank enter into an arrangement with a bank and offer payment-related services alongside it. In practice that means a sponsoring bank issues the stored value and you build the product on top.
What can a non-bank hold in its own name?+
Authorisation to act as a system operator under section 4(2)(c) of the National Payment System Act 78 of 1998, or registration as a third-party payment provider under Directive No. 1 of 2007. A third and much rarer option is designation as a clearing system participant by Gazette notice under section 6(3)(a), which is the only way a non-bank may clear. Settlement is closed to non-banks entirely.
How much capital is required?+
None. No minimum capital, own-funds, net-asset or guarantee figure is prescribed for a system operator, a third-party payment provider or a designated clearing system participant, and that is a confirmed absence rather than a gap in the research. The only financial obligation in the criteria the Reserve Bank approved is clause 3.3.4, that the operator be adequately insured against claims by clients and beneficiaries, and no minimum sum insured is stated.
When must a system operator be authorised?+
Authorisation is compulsory once the applicant processes more than 10,000 payment transactions a month or a combined payment value above R10 million a month, under clause 3.1(e) of the approved criteria; below those thresholds it is discretionary. The published fees are R10,000 to apply, R2,000 once-off per payment system and R2,000 a year per payment system, all excluding VAT. Registering as a third-party payment provider costs nothing.
How long does a decision take?+
There is no statutory period anywhere - not in the Act, not in either 2007 directive, and not in any of the three draft frameworks. The only published standard is 21 working days after all the required information and documentation has been received, for both system-operator authorisation and third-party-payment-provider registration. From first call, plan on six to twelve months end to end, with the sponsoring bank usually setting the pace.
Who receives the application now that PASA's recognition is being withdrawn?+
That is the honest gap. The central bank is withdrawing its recognition of the Payments Association of South Africa as payment system management body in two phases, 11 August 2026 and 2 September 2026, with functions and staff moving to the Reserve Bank and to PayInc. No official page identifies the receiving body for system-operator and third-party-payment-provider applications after 2 September 2026, so we confirm the addressee with the National Payment System Department before filing.
Is the new activity-based framework in force?+
No. Three drafts exist - 3 March 2025, 14 November 2025 and May 2026 - and the May 2026 version is issued under section 12(1) of the NPS Act and marked 'Draft for consultation'. The draft exemption notice that would take e-money issuance outside the business of a bank, under section 1(1), paragraph (cc) of the Banks Act 94 of 1990, has not been gazetted either. The March 2025 draft proposed R5,000,000 of initial capital for issuing e-money, R3,000,000 for third-party payments and R6,000,000 each for clearing and settlement; the current drafts moved those figures into an annexure that is not published.
Do I need a trust account for client money?+
Not under the current regime. Directive No. 1 of 2007 contains no safeguarding, segregation or reconciliation rule at all, and Directive No. 2 of 2007 imposes only the negative duty at clause 3.1.4 that a system operator must not pay or transfer client funds through its own account. Segregation is therefore a contractual demand from the sponsoring bank, not a regulatory one. The draft framework would require a trust account, which is one more reason to build as though it already applied.
Can a payment company move money cross-border in its own name?+
Only as an Authorised Dealer or an Authorised Dealer with Limited Authority. Regulation 2(1) of the Exchange Control Regulations 1961 says no person other than an authorised dealer may buy, borrow, sell or lend foreign currency other than with one, and regulation 22 carries R250,000 or five years. An ADLA is licensed by the Financial Surveillance Department on R2 million, R3 million, R5 million or R8 million of unimpaired capital by category, needs local incorporation under the Companies Act 2008, personally held shares and fit-and-proper shareholders and directors. Separately, Common Monetary Area low-value cross-border EFT of R5 million or less must run through TCIB from 1 April 2027 under Directive No. 1 of 2025.
Why South Africa rather than Mauritius or Kenya?+
South Africa asks no capital for either route a non-bank can take, has the deepest banking sector on the continent to sponsor from, and gives you PayShap and SAMOS to build on. What it will not give you is an e-money licence in your own name, and it prints no decision deadline. Mauritius licenses a large e-money issuer on Rs 5,000,000 and decides in 60 working days; Kenya licenses one on KES 20,000,000 and has the mobile-money market to match. Groups selling across the region often register in South Africa for reach and license e-money next door.
Can I issue e-money?+
Not as a non-bank. Only registered banks may (PP NPS 01/2009).
What can I hold?+
System operator authorisation, or TPPP registration.
Capital?+
None prescribed. Insurance only (cl. 3.3.4).
When is authorisation compulsory?+
Above 10,000 transactions or R10m a month.
How long?+
No statutory clock; 21 working days published, 6-12 months realistic.
Who receives the file?+
Not published after 2 September 2026; we confirm with the SARB.
Is the new regime live?+
No. Three drafts, none gazetted.
Trust account?+
Not required now; the bank imposes it by contract.
Cross-border?+
Through an Authorised Dealer, or your own ADLA (R2m-R8m).
vs Mauritius / Kenya?+
No capital here; they license e-money, South Africa does not.
Client notes
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“As a software development crew at FewMoreTaps OÜ, we've had the pleasure of working with Prifinance on some key financial moves.First of all, navigating the world of corporate banking and finance can be a maze, but Prifinance made it feel like a walk in the park. They helped us set up a corporate bank account without the hassle of jumping on a plane or drowning in paperwork. Everything was done remotely, smoothly…”
Google
“I had their assistance in company registration and I would recommend them. They were answering all my clarification during the process and offering all their supportThank you Daniel and Irinia”
Google
“We found PRIFINANCE COMPANYvia the Internet and asked for help in organizing the opening of their company in Estonia. PRIFINANCE COMPANY specialists helped us a lot with this. Their professional, competent approach and knowledge of their business left us with only the best impressions.”
Google
“I'm thrilled with my experience with PriFinance! They helped me obtain a crypto license in Estonia without any hassle. The team was super understanding and always available to answer my questions and assist. It was great to see how they put effort into preparing the documents to ensure everything went smoothly. I'm delighted with the outcome and highly recommend PriFinance to anyone looking to get a license…”
Google
“Opening an account with Prifinance in a Swiss bank was such an easy and quick process that I was shocked. It all started with the first call, where I received detailed guidance on the required documents and the entire procedure.One of the key highlights was their attention to detail. As someone who usually gets tangled up in paperwork, I was pleasantly surprised when they sent me all the documents and…”
Google
“I recently had the pleasure of working with Boris.. and I must say, it was a fantastic experience. Boris went above and beyond to assist me with my residency needs. His professionalism, knowledge, and dedication truly stood out. I highly recommend working with Boris and the team!”
Google
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