For more than a decade, South African gift cards have existed
largely within the consumer-protection space. Section 63 of the
Consumer Protection Act 68 of 2008
("CPA") treats a gift card as a
"pre-paid certificate, card, credit, voucher or similar
device" issued by a supplier that undertakes to provide goods
or services up to the stored value. The CPA guarantees, among other
things, a minimum three-year validity period and prohibits the
early expiry of the residual balance. Crucially, however, the
CPA's remit is limited: it was drafted on the assumption that
the same party that issues the voucher is also the merchant that
ultimately redeems it. That assumption is increasingly out of step
with modern payment architectures, and the South African Reserve
Bank ("theSARB") has now signalled a
decisive shift.