The South African Reserve Bank's November 2025 draft
Directive in respect of specific payment activities makes a subtle
but material change to the way "e‑money" is defined
and supervised.
This change has direct implications for fiat‑referenced
crypto assets, including stablecoins, and could bring certain
issuers squarely within the scope of the Draft Authorisation
Framework.
The earlier position: March draft tied
"e‑money" to general acceptability
In the March 2025 version of the Draft Directive, the term
"e‑money issuer" was defined as an entity that
issues electronically stored monetary value upon receipt of funds.
The definition further clarified that the "value" is
represented by a claim on the issuer, which is
"generally accepted as a means of payment
by persons other than the issuer and is redeemable for physical
cash or a deposit into a payment account, on demand".
