Dear Colleagues
Rebosa recently held its Annual General Meeting, which highlighted the many achievements we’ve accomplished for the industry, all made possible through the support of our members. Your membership fees fund the legal expertise, consultations, and representation that safeguard the interests of not only property practitioners but the industry at large.
Much of our work takes place quietly behind the scenes, from drafting submissions, engaging on legislation, to challenging unfair or impractical regulations. Yet, the results of this work have brought meaningful improvements to the way our industry operates.
Because of your continued support, we secured many key provisions in the Property Practitioners Act, including the ability to operate without trust accounts (under guidelines), three-year FFCs without administrative red tape, recognition of one FFC for multiple firms, and reduced CPD fees to name a few.
More recently, your contributions have enabled Rebosa to:
- Challenge and overturn the PPRA’s R640 “admin fee” for FFC renewals
- Ensured that ‘Valid’ vs ‘Compliant’ BEE certificates are accepted for FFC renewals, preventing hundreds of firms from being deregistered and saving the jobs of thousands of agents employed by them.
- Secure the waiver of historical penalty fees for agents returning to the industry who had not deregistered with the authority
- Negotiate the reintroduction of the 50:50 split of trust account interest with the PPRA. (until August 2024 PPRA were still extracting 100%)
- Obtain an E1 exemption allowing members to use a more practical Mandatory Disclosure Form
- Lobby for the 27 months temporary extension of the compliance period for candidate property practitioners who are in the process of completing the Occupational Certificate: Real Estate Agent (Qualification ID 118714).
Each of these outcomes represents months of dedicated advocacy and engagement, made possible through your membership. While we know your immediate concerns often relate to resolving PPRA queries, these broader interventions create the regulatory environment that allows you to operate with greater certainty and fairness.
We are equally proud of our transformation efforts through the Rebosa Business Leader Programme, which provides bursaries to deserving candidates from historically disadvantaged backgrounds, equipping them with the skills needed to build operationally successful businesses. Many of our graduates have since launched their own enterprises and are now paying it forward by creating employment opportunities for others and contributing back to both the real estate ecosystem and the programme that supported them.
Thank you for standing with us. Your membership gives Rebosa its strength, its voice, and its ability to drive positive change across the industry.
Important reminders follow in this report.
Jan le Roux
Chief Executive
FFC Renewals
The deadline for FFC renewals is Friday, 31 October.
Rebosa has endorsed the PropCert platform to make the renewal process easier for our members. Although the service fee is R150, Rebosa covers this cost, so the platform is completely free for members. We encourage members who have not yet renewed to use PropCert, which provides a straightforward way to submit, track, and manage your application.
Register using the following link:
For those who have already submitted via PropCert but have not yet received their FFC, there is no cause for concern.
We are monitoring all PropCert applications in real time. The platform automatically logs the exact date and time each submission is made and tracks all related communications, including confirmation emails and system-generated reminders.
The PPRA is currently processing over 50,000 FFCs while experiencing intermittent IT disruptions, which makes this a significant undertaking.
Please note that your current FFC remains valid until 31 December, and your new FFC only needs to be active from 1 January 2026. We still have two months to ensure your certificate is issued.
If you renewed your FFC directly with the PPRA, please email: mailto:ffcrenewals@theppra.org.za for assistance, as we have no automated system outside of PropCert to track these applications.
CPD
The PPRA CPD portal has been non-operational for several months. The PPRA CEO has confirmed on their official Facebook page that CPD points for 2024 and 2025 will not affect FFC renewals.
To date, no 2025 CPD points have been uploaded on agents’ portals, regardless of whether the CPD modules were completed through the PPRA or the Charter Academy.
Rebosa endorses the Charter Academy CPD programme, which fully meets PPRA requirements. The programme covers over 30 modules, automatically issues certificates upon completion, and submits results directly to the PPRA. Charter Academy also pays the PPRA fee on your behalf. The programme is R300 cheaper, making it more cost-effective.
We encourage members to utilise this alternative CPD programme. It offers a simpler, more reliable way to complete CPD while allowing Charter to verify results efficiently and assist with any PPRA-related queries.
https://charteracademy.co.za/cpd/
Financial Intelligence Centre
We welcome that the Financial Action Task Force (“FATF”) unanimously agreed to remove South Africa from its grey list. With greylisting behind us, it bodes well for investors looking at South Africa‘s property market with renewed confidence.
This development does not signal a lessening of compliance expectations. Agents must remain vigilant as regulatory supervision is front-and-centre, and you still need to apply a robust risk-based approach under the Financial Intelligence Centre Act and related legislation. “Lifting the mantle of the grey list does not mark the end of this endeavour but lays the foundation for the next phase.” (FIC).
Read the full FIC media release:-
In September, we held a FIC training webinar with Maryna Botha, STBB. Revised RMCP templates, checklists and guidelines are available to all our members at no cost. You can watch the recording using the following link:-
Passcode: 6yc0G!.a
We’ve also created a folder with the following resources:
- FIC Presentation: Key Financial Intelligence Centre Act Obligations: Estate Agents
- STBB Presentation: FICA Update
- Draft RMCP Template
- Guide to the Draft RMCP Template
Access the shared folder using the link below:-
https://drive.google.com/drive/folders/1EPb2TARSQ-KYem809Sm9qQ5Za2zLapIq?usp=sharing
Important Notes on the RMCP Template:
- The template must always be used together with the guide.
- It is provided in MS Word so you can adapt it to your firm’s specific risk profile.
- Brand it as appropriate for your agency.
- To update with your agency’s name: open the Word document, select Replace → enter ESTATE AGENCY in Find what, insert your agency name in Replace with, then click Replace All and save.
- The Risk Management and Compliance Programme (“RMCP”) must be developed, documented and maintained in a manner that is specific to the risk profile, operations, structure, products, services and geographies of the Firm. It cannot be a generic replication of the template without customisation to the Firm’s actual risks, controls, systems, business model and regulatory environment. Any RMCP that is merely copied, pasted or superficially adopted shall be deemed non-compliant, and may expose the Firm to regulatory sanctions, enforcement action, or remedial requirement by the Financial Intelligence Centre.
Temporary Extension of the Compliance Period for Candidate Property Practitioners to Complete Educational Requirements and Write the PDE 4 Examination
Following extensive lobbying and consultation, we acknowledge and are grateful for the PPRA’s decision to grant a temporary 27-month extension of Regulation 33.4.5.
This measure is, at best, a short-term reprieve and not a genuine solution to the systemic failures in the implementation of the PP Act and Regulations.
For almost four years, the industry has awaited the establishment of clear educational standards, the implementation of the Occupational Certificate (OC), practical training and the functional administration of the External Integrated Summative Assessment (EISA), yet progress remains painfully slow. SSETA and SAQA have failed to deliver the necessary guidelines and approval of the exam exemplar, exam schedules, national venues, and cost structures, leaving thousands of candidates in regulatory limbo.
This repeated pattern of extensions, while ostensibly providing relief, merely highlights a lack of accountability and urgency from the very bodies mandated to professionalise our sector.
Other professions are held to firm standards, with timely and transparent pathways for qualification and compliance. Property practitioners, who form a cornerstone of the economy, continue to be treated with disregard and bureaucratic indifference. Extensions without tangible implementation cannot substitute for the credible, structured, and sustainable training and education framework the sector has been waiting for.
We expect more and will continue to fight for a feasible, simple, and practical solution to our industry’s qualification standards. One that removes unnecessary red tape, opens the profession to more people, accelerates entry into the market, and genuinely supports transformation rather than hindering it.
Download the PPRAs notice using the link below:-
REBOSA Mandatory Disclosure Form – Rebosa Members Only
Rebosa applied to the Property Practitioners Regulatory Authority (PPRA) for a conditional exemption from the provisions of section 67(1) of the Property Practitioners Act, 22 of 2019, read together with regulation 36 of the Regulations.
These provisions require that a Mandatory Disclosure Form (MDF), in the prescribed format, be completed and annexed to every sale and lease agreement. However, the prescribed MDF has presented a number of practical challenges, particularly within the residential sector. Additionally, no official version existed for residential lease transactions.
We are pleased to confirm that the PPRA has granted Rebosa and its members a conditional exemption from section 67 and regulation 36, specifically for residential property transactions. This exemption is granted on the proviso that Rebosa has developed and submitted a revised version of the Mandatory Disclosure Forms, which members may now use in place of the prescribed format. These revised MDF documents have been designed to address the practical difficulties previously encountered and ensure appropriate coverage for both sale and lease agreements in the residential sector.
Members who choose to utilise the Rebosa MDF templates must ensure that:
- The forms are completed using the official Rebosa templates provided; and
- A copy of the PPRA exemption letter is retained in their compliance files for inspection purposes.
- PPRA inspectors have been formally advised that Rebosa members are permitted to use the Rebosa MDFs. However, during inspections, they will request the exemption letter as confirmation of both Rebosa membership and the authority to use the exempted forms.
Download the documents using the link below:-
https://www.rebosa.co.za/rebosa-mandatory-disclosure-form-rebosa-members-only/
Promotion of Access to Information Act (PAIA), 2000 (Act No. 2 of 2000)
To support compliance, we have developed PAIA Manual templates tailored for property practitioners and estate agencies. These templates are available for download below and can be customised for your business. Please ensure that your PAIA Manual is published on your website and submitted to the Information Regulator, in line with current legal requirements.
Download the documents using the link below:-
https://www.rebosa.co.za/introduction-to-paia/
Twelve-Month FFCs
While the PPRA continues to experience ongoing IT challenges, we remain committed to applying pressure on the Authority to resolve these issues urgently so that one-year FFCs can be issued. The continued non-issuance of one-year FFCs creates a significant barrier to entry for new candidates, who already face substantial costs related to education and compliance requirements and are unlikely to earn an income during their initial months in the industry.
REBOSA AGM
Rebosa held it’s its thirteenth Annual General Meeting on 16 October 2024. You can read all about our year in review in our Chairman’s Report by accessing the link below:-
https://www.rebosa.co.za/rebosa-agm-2024-25-chairmans-report/
REBOSA Leadership Changes
Rebosa is pleased to announce the appointment of Mrs Xoliswa Tini to its Board of Directors following the recent Annual General Meeting. As the founder and Managing Director of Xoliswa Tini Properties, Xoliswa brings a wealth of industry expertise, entrepreneurial acumen, and a proven track record of success in the property sector. Her experience and insight will undoubtedly enhance the board’s strategic direction and further Rebosa’s mission to strengthen the industry.
We also extend our heartfelt gratitude to Mr. Bryan Biehler, CEO of Huizemark, whose long-term tenure on the board concluded this year. Bryan’s exceptional dedication and invaluable contributions have left a lasting impact on Rebosa’s work. He spent many years serving on the Property Sector Charter Council’s technical committee and has been a dedicated advocate for the Rebosa Business Leader Programme. While his term on the board has concluded, we look forward to his continued involvement and support in advancing Rebosa’s work and remain grateful for his unwavering support and service.
Application of the Consumer Protection Act to Residential Leases: Els v Venter (2025 ZASCA 163)
The SCA judgment in Els v Venter (2025 ZASCA 163) clarifies that the Consumer Protection Act (CPA) does not automatically apply to every residential lease, but is limited to leases concluded “in the ordinary course of business” by a lessor who continually markets rental properties.
In the recent SCA judgment of Els v Venter (2025 ZASCA 163), the Court clarified that the Consumer Protection Act (CPA) does not automatically apply to every residential lease concluded by a lessor.
The Court emphasised that the definitions of ‘rental’, ‘consumer’ and ‘supplier’ in the Act all turn on whether the letting is conducted ‘in the ordinary course of business’ by the lessor. Only when the lessor is engaged in the continual marketing or supply of rental premises, and the transaction falls within that business, will the lease qualify as a consumer agreement under the Act.
Private, once-off leases by persons not habitually engaged in property letting therefore fall outside the scope of the CPA.
The judgment provides welcome certainty for landlords, property practitioners and managing agents
involved in residential leasing.
Legal and conveyancing commentators have noted that the decision will require practitioners to more carefully assess a landlord’s business activities when drafting lease agreements, ensuring that CPA compliance clauses are included only where the lessor operates in the ordinary course of business.
We will unpack this in more detail in our next report once our attorneys have provided us with sound advice for our rental agents.
Read the media summary of the judgment here:
https://www.supremecourtofappeal.org.za/images/SCA2025-163ms.pdf
General
All PPRA notices are published on our website (rebosa.co.za) under the ‘PPRA Notifications’ tab, in chronological order as they are released by the PPRA. If you have trouble navigating the PPRA website, everything is available here, and the search bar on our site makes it easy to find what you need.
