SARB's Amended Authorisation Framework: Closing The Loop On Closed Loop And TPPPs

The South African Reserve Bank published an amended version of the Draft Authorisation Framework in respect of specific payment activities, on Friday, 14 November.

We have reviewed the November draft against the draft circulated in March earlier this year, and note material changes to the regulation of closed‑loop payment instruments and third‑party payment providers (TPPPs). We previously raised concerns regarding the treatment of gift cards under the Draft Authorisation Framework – and welcome the changes in the November draft.

Closed‑loop payment instruments and systems

The November draft significantly expands and clarifies the regulation of closed‑loop arrangements. Whereas the March draft simply required registration of closed‑loop systems, the November draft introduces a detailed registration regime, including scope, thresholds and compliance expectations. Notable developments include: