This dated narrative contains pending corrections. Read the notes, then expand the original text.
SettleADebt C_ZA PASS-15 — South Africa
National credit-reporting, debt-review clearance and correction gateway
Focused component: Reviewed P05 D14 — credit reporting and clearance.
Fresh research access: 26 October 2026 PDT; 27 October 2026 UTC and SAST. Exact source-opening clock times were not logged and are unknown.
Mode and provenance: Regular Chat with public primary-source browsing. The coordinator-selected model family and power are not independently exposed here; no Pro, quota-reset, measured-ranking or independent-review claim is made. P06, P10, P11 and P13 remain saved but unreviewed and are not adopted as accepted premises. P14 is preserved as a targeted P12 correction only.
Scope: This pass maps the national NCA reporting, retention, dispute, paid-up-removal and ordinary debt-review-clearance routes. It does not inspect any real credit report, bureau database, consumer, provider, debt counsellor, order, judgment or account.
Principal disposition
Four mechanisms must be kept separate:
- Section 71 debt-review clearance: a debt counsellor issues a clearance certificate after the statutory payment or continuing-mortgage predicates are met. Receipt of the certificate requires bureaux and the national register to remove the debt-rearrangement fact, associated defaults and records showing agreements were subject to rearrangement.
- Section 71A paid-up removal: after settlement of an obligation that generated specified adverse information or a judgment-debt listing, the credit provider reports settlement within seven days and the bureau removes the adverse listing within seven days after receiving that information.
- Section 72 accuracy challenge: a consumer challenges inaccurate, outdated, incomplete, prescribed, fraudulent or otherwise disputed information; the holder must seek credible evidence and either substantiate or remove it within the prescribed process.
- Ordinary retention expiry: accurate information can remain only for the applicable maximum retention period, subject to earlier removal under §§71, 71A, rescission or another operative rule.
These routes are not interchangeable. A paid-up listing is not necessarily a clearance certificate. A clearance certificate does not itself rescind a judgment. A dispute does not automatically erase accurate information or extinguish the underlying debt. A paid judgment can lose its adverse listing under §71A without the judgment itself being judicially rescinded. DTIC+3
The 2014 amendment materially broadened ordinary §71 clearance. A consumer need not always pay off an eligible continuing housing mortgage before clearance: the statute allows clearance where the consumer can meet future obligations under the rearranged qualifying mortgage or another prescribed long-term agreement, has no arrears on it, and has settled every other included agreement in full. The official Form 19 and original regulation 27 still reflect older “all obligations paid” wording; they cannot silently narrow the later Act. That creates an instrument-version conflict that must remain visible. DTIC+3
The final 2015 regulations establish maximum retention periods, including five years for payment-profile facts, one year for specified adverse classifications, and the earlier of five years or identified earlier-removal events for civil judgments. Those are maximum periods, not guaranteed minimum display periods, and §§71/71A can require earlier removal. South African Government+1
G1. Current national reporting perimeter
G1.1 Source chain and currentness
The integrated dtic NCA compilation supplies the amended §§70–73 text and marks the 2019 debt-intervention provisions as pending. It is useful but not a certified October 2026 consolidation; the final 2014 amendment and its March 2015 commencement were therefore read separately. Nothing from the held 2019 debt-intervention module is used here. DTIC+1
The operative reporting regulations used here are:
- the original 2006 National Credit Regulations, especially regulations 17–20 and 27; and
- the final March 2015 amendments replacing the retention table and adding regulations 19(6)–(13).
The 2015 Gazette says those amendments took effect on publication, 13 March 2015. A 2025 credit-information draft was later withdrawn in full; it is not treated as a current amendment. South African Government+2
G1.2 What counts as consumer credit information
NCA §70 permits bureau information encompassing, among other things:
- credit history;
- payment patterns;
- default or non-payment history;
- debt-rearrangement and enforcement information;
- termination of credit agreements;
- financial history;
- employment and business history;
- identity and address information; and
- other prescribed information.
A credit bureau must accept properly submitted information, allow correction and challenge without charge where the Act requires it, verify accuracy, retain information only for the prescribed period, promptly remove prohibited or removal-required information, report only for lawful prescribed purposes and avoid knowingly or negligently issuing inaccurate reports. DTIC+1
The fact that information is legally reportable does not establish that every item is accurate, current or still within its retention period. Conversely, the absence of a current listing does not itself prove the underlying debt never existed, was invalid, was settled or prescribed.
G1.3 Reporting-source accuracy and advance notice
Regulation 19(3) requires reporting sources to take reasonable steps to ensure submitted information is:
- accurate;
- current;
- relevant;
- complete;
- valid; and
- not duplicated.
Regulation 19(4) requires at least 20 business days’ notice before submitting specified adverse consumer-behaviour or enforcement classifications, such as default, slow payment, being handed over, legal action or write-off. That notice rule is tied to those categories; it should not be expanded into advance notice for every neutral payment-profile update. South African Government+1
The 2015 additions further state that:
- adverse information may not be submitted until required instalments have remained unpaid for at least three consecutive billing cycles;
- it may not be submitted if the arrears are settled during the notice period; and
- it may not be submitted if the consumer disputes liability within the regulation 20 dispute period.
Those are pre-listing gates, not a determination that the account balance is invalid or that a dispute must ultimately succeed. South African Government+1
G1.4 Maximum retention periods
The 2015 regulation 17 table provides the following maximum display/use periods:
| Category |
Maximum period or earlier-removal event |
| Complaint details and whether rejected |
Six months; no displayed information on upheld complaints |
| Enquiries |
One year |
| Factual payment profile |
Five years |
| Adverse enforcement classification |
One year or the §71A period |
| Adverse behaviour classification |
One year or the §71A period |
| Debt restructuring |
The §71(1) period or until a clearance certificate is issued |
| Civil/default judgment |
Earlier of five years, court rescission, abandonment under the identified Magistrates’ Courts Act route, or the §71A period |
| Maintenance judgment |
Until rescinded |
| Sequestration |
Five years or until rehabilitation |
| Rehabilitation order |
Five years |
| Administration order |
Five years or until rescission |
A maximum retention period does not permit continued reporting after a mandatory earlier removal event. It also does not require deletion of every factual payment entry merely because one adverse label has been removed.
G1.5 Paid arrears and payment-profile updates
Where arrears underlying adverse information are settled, regulation 19(10) requires the source to advise the bureaux in its next data submission; the bureau must update the consumer’s record within seven days after notification. This is different from §71A’s seven-day credit-provider reporting duty following settlement of an obligation subject to the specific adverse categories listed in §71A. South African Government
A record can therefore need an update without the entire account history disappearing. “Paid,” “updated,” “adverse listing removed” and “whole payment history deleted” are different outcomes.
G1.6 Free access and inspection
NCA §72 provides a right to inspect one’s credit-bureau or national-register information without charge:
- once during any 12-month period;
- when ordered by a court or Tribunal; and
- once within a reasonable period after a successful challenge, to verify correction.
Additional inspections may attract the prescribed fee, if any. A credit provider may not require a prospective consumer to obtain their own report for a credit application or §81 assessment. DTIC
The free report is an access right, not a promise that a score will increase, a listing will be removed or new credit will be granted.
G1.7 Disputes and verification
A person may challenge:
- information proposed for reporting; or
- information already held by a bureau or the national register.
The challenge and investigation must be available without charge. The holder must seek credible evidence. Within the prescribed process it must either supply that evidence or remove the information and all record of it if it cannot substantiate the item. The information may not be reported while the challenge remains unresolved. DTIC+1
Regulation 20 gives 20 business days after filing the challenge to undertake the §72(3) steps. If information is removed, the bureau must inform:
- the consumer;
- parties to whom the information was reported during the previous 20 business days; and
- all other registered credit bureaux. South African Government+1
The NCR’s December 2024 guideline says a primary bureau should mask challenged information as soon as practicable and no later than five business days after receiving a complete challenge. That five-day masking period is regulator guidance; the 20-business-day investigation period comes from regulation 20. NCR+1
G1.8 Escalation after credible evidence
If the holder supplies credible evidence supporting the challenged information, §72(4) gives the challenger 20 business days after receiving that evidence to approach the NCR in the prescribed manner for investigation as a §136 complaint. This is a different 20-business-day period from the bureau’s regulation 20 investigation period. DTIC+1
P10’s broader enforcement analysis is unreviewed and is not adopted here. P15 records only the statutory reporting-dispute gateway.
G1.9 Prescription-reporting boundary
Original regulation 19(5) correctly refers to the Prescription Act 68 of 1969. The 2015 inserted regulation 19(6) refers to “Act 68 of 1998,” an apparent textual error. P15 does not silently correct the final Gazette or decide the legal treatment of the drafting inconsistency. South African Government+1
The underlying reporting proposition is conditioned on the debt actually having prescribed. A consumer’s unsupported assertion does not itself prove prescription. P12’s prescription report remains unreviewed and is not adopted as a substantive premise.
G1.10 POPIA crossover
POPIA operates alongside sector-specific NCA credit-information rules. Where another law supplies more extensive lawful-processing conditions, those more extensive conditions can prevail. POPIA also requires reasonable steps to keep personal information complete, accurate, not misleading and updated where necessary. Justice+1
POPIA’s retention principle generally prohibits keeping personal information longer than necessary unless a statutory, contractual, lawful-purpose or other recognised basis applies; it also requires deletion, de-identification or restricted processing when the legal retention basis falls away. Justice
This is only the necessary crossover. Full privacy, information-regulator, cross-border-processing and foreign privacy analysis remains deferred.
G2. Ordinary debt-review clearance
G2.1 Two statutory clearance branches
Section 71(1), as substituted in 2014, requires a debt counsellor to issue a clearance certificate within seven days after one of two branches is established.
Branch A — all included obligations satisfied
The consumer has satisfied every obligation under every credit agreement subject to the rearrangement order or agreement.
Branch B — qualifying continuing agreement remains
The consumer demonstrates:
- financial ability to meet future obligations under the rearranged:mortgage agreement securing credit used to purchase or improve immovable property; oranother prescribed long-term agreement;
- no arrears on that continuing agreement; and
- settlement in full of every other credit agreement included in the rearrangement. DTIC+1
The section says seven days, not seven business days. P15 does not convert that period into business days or invent a precise midnight rule.
G2.2 Mortgage branch limits
The continuing-mortgage branch does not mean:
- every mortgage can remain unpaid;
- any secured loan qualifies;
- arrears can remain;
- a consumer can self-certify financial ability; or
- every housing-related obligation is a qualifying mortgage.
The agreement must fit the statutory mortgage description, secure credit for purchase or improvement of immovable property, be part of the rearrangement and satisfy the future-ability and no-arrears predicates.
G2.3 “Other prescribed long-term agreement” gap
Section 71(1)(b)(i)(bb) contemplates another prescribed long-term agreement. P15 did not establish a currently operative regulation identifying any such additional class. It is therefore held open rather than populated with an invented product category.
G2.4 Debt-counsellor measures and proof
Section 71(2) requires the debt counsellor to apply the prescribed measures when assessing the continuing-agreement branch. The final current form of every evidentiary measure was not established in a fully harmonised regulation. The Tribunal filing table nevertheless contemplates evidence of:
- the rearrangement agreement or court order;
- the application to the debt counsellor;
- the debt counsellor’s reasons for refusal or failure;
- proof that all other obligations are settled; and
- proof of financial ability regarding the continuing mortgage or qualifying long-term agreement. NCR
No actual order, mortgage statement, paid-up letter, affordability calculation or arrears history was examined.
G2.5 Refusal or failure to issue
If the debt counsellor decides not to issue, or fails to issue, the consumer may apply to the NCT for review under §71(3). The Tribunal may order issuance if satisfied that the consumer meets §71(1). DTIC+1
The 2015 Tribunal material identifies Form TI.71(3) and supporting documents, but P15 does not certify a current standalone filing deadline for this application. The rules table displayed “n/a” for that timing cell in the material reviewed; no deadline is invented.
G2.6 Filing after issuance
Within seven days after issuing the certificate, the debt counsellor must file a certified copy with:
- the national register; and
- all registered credit bureaux.
If the debt counsellor fails, the consumer may file the certified copy with the NCR and lodge a complaint against the debt counsellor. DTIC
The consumer’s substitute-filing branch presupposes that a certificate has actually been issued. It is not the same as the Tribunal-review route when issuance itself is refused.
G2.7 What bureaux must remove after clearance
Upon receipt of the certificate, the bureau or national register must expunge:
- the fact that the consumer was under the relevant debt-rearrangement order or agreement;
- defaults that precipitated or were considered in the rearrangement; and
- records identifying particular agreements as subject to the rearrangement. DTIC+1
The section does not say that every neutral historical account entry, every unrelated judgment or every fact outside those categories must disappear.
G2.8 Clearance is not judgment rescission
Section 71(6) separately requires removal of judgment information upon receipt of a court order rescinding the judgment. That is a distinct trigger from an ordinary clearance certificate. DTIC
A paid judgment may also be subject to §71A adverse-listing removal. But removing the bureau listing after payment does not itself convert payment into judicial rescission of the judgment.
G2.9 Current 2026 filing process
NCR Guideline 001/2026 designates the Credit Bureau Association debt-counselling platform for submission of certified Form 19 certificates and supporting documents. It says the filing should include paid-up or legally uncollectable account confirmations, rescinds earlier filing guidance and establishes the updated platform process. NCR+1
The guideline is procedural guidance. It does not amend §71’s eligibility requirements and cannot narrow the statutory continuing-mortgage branch.
G2.10 Form 19 and regulation 27 conflict
The public Form 19 still uses older wording stating that all obligations were discharged, and regulation 27 of the original 2006 regulations likewise says a certificate is issued only when all debt obligations are fully satisfied. Those texts predate the 2014 amendment’s continuing-mortgage branch. NCR+1
P15 treats this as a source-version conflict:
- the later Act controls the statutory eligibility gateway;
- the form and old regulation remain evidence of outdated drafting and operational risk;
- no assumption is made about how every current platform field handles the mortgage branch.
G2.11 Withdrawal, termination and clearance are distinct
NCR Circular 2 of 2025 warns about commercial “debt review removal” services and directs attention to separate withdrawal guidance. A consumer who seeks to leave debt review before satisfying §71’s clearance criteria raises a withdrawal or procedural-status question, not an automatic clearance question. NCR
P15 does not resolve the full withdrawal law, court-order rescission process or private “removal service” contract.
G3. Disputes, paid-up removal and adverse branches
G3.1 Section 71A paid-up removal
Where an obligation under a credit agreement was the subject of:
- adverse consumer-behaviour classification;
- adverse enforcement classification;
- an adverse listing in the payment profile; or
- a judgment debt,
the credit provider must send settlement information to all registered bureaux within seven days after settlement. Each bureau must remove the adverse listing within seven days after receipt. DTIC
If the credit provider fails to send the settlement information, the consumer may complain to the NCR. P10’s broader complaint process is not adopted here. DTIC
G3.2 Defined adverse categories
Section 71A defines adverse consumer behaviour through examples such as delinquent, default, slow-paying, absconded and not-contactable. Adverse enforcement action includes being handed over, legal action and write-off. DTIC
These defined adverse classifications are narrower than every piece of factual payment history.
G3.3 Payment-profile facts versus adverse listing
The retention table allows factual payment-profile information for up to five years. Section 71A requires removal of the adverse listing after settlement. Those provisions should be read together:
- the specific adverse label must be removed when §71A applies;
- the statute does not necessarily command deletion of every factual payment event relating to the account; and
- retained information must still be accurate and within the lawful maximum period. South African Government+1
G3.4 Paid judgment versus rescinded judgment
Three separate states are possible:
| State |
Reporting consequence |
| Judgment remains unpaid |
Retention subject to regulation 17 and any other applicable rule |
| Capital amount of judgment settled |
Credit provider must report settlement; bureau updates/removes the adverse listing under §71A/regulation 19(11) |
| Judgment rescinded by court |
Bureau must expunge all judgment information under §71(6) |
Payment and rescission are therefore not synonyms.
G3.5 Historical 2014 amnesty
The 2014 regulations created a one-time removal exercise for adverse information existing on their effective date and an ongoing paid-up-judgment mechanism. They required the old stock of adverse information to be removed within two months, with sharing across bureaux, and prohibited reuse or relisting of removed information. They did not extinguish underlying obligations. South African Government+2
This historical amnesty should not be described as the present general rule for every new listing. Current routine paid-up removal is principally addressed through §71A and the 2015 reporting amendments.
G3.6 Accuracy dispute with credible evidence
If the reporting source or bureau finds credible evidence supporting the challenged information, it may retain the information after providing the evidence, subject to the dispute process. The consumer then has the separate §72(4) escalation period after receiving the evidence. DTIC
An accurate listing is not removed merely because it is inconvenient, lowers a score or is disputed without substantiation.
G3.7 Accuracy dispute without credible evidence
If the holder cannot find credible supporting evidence, it must remove the information and all record of it, subject to the Tribunal’s limited power concerning frivolous or vexatious requests. DTIC+1
Regulation 20 additionally requires notice to the consumer, recent report recipients and all other registered bureaux after removal. South African Government
G3.8 Erroneous debt-review flag
An erroneous debt-review flag can be challenged under §72 as inaccurate information. A valid debt-review flag, by contrast, is ordinarily removed through:
- §71 clearance;
- a separately valid withdrawal/status process; or
- another operative order or correction basis.
A consumer cannot use an accuracy dispute to erase a fact that is accurate and lawfully reportable merely because clearance criteria have not yet been met.
G3.9 Prescription assertion
A source may not submit information about a debt that has actually prescribed under the applicable law, but the final 2015 regulation contains an apparent statute-year error. P15 therefore does not decide prescription status or resolve that drafting issue. South African Government+1
An unsupported assertion of prescription is still a dispute requiring evidence; it is not an automatic deletion command.
G3.10 No score, credit or debt-forgiveness guarantee
Removal or correction of information does not guarantee:
- a particular credit score;
- immediate score improvement;
- new-credit approval;
- a specific interest rate;
- cancellation of the underlying debt;
- rescission of a court order; or
- termination of debt review.
Those outcomes depend on separate facts, systems and laws.
G4. Fourteen fictional reporting and clearance workflows
All examples are fictional. No actual report, consumer, account, bureau, counsellor, creditor, mortgage or judgment is involved.
Workflow 1 — all included unsecured debts settled
Assumed facts
- A valid ordinary debt-rearrangement order covers four unsecured credit agreements.
- All four obligations are fully settled.
- No continuing mortgage or other long-term agreement remains.
Classification
Section 71(1)(a) requires the debt counsellor to issue a clearance certificate within seven days after the qualifying event is established. After issuance, the counsellor has seven days to file it with the national register and all registered bureaux. On receipt, the relevant debt-review records and associated defaults must be expunged. C_ZA-P15-C034, C039, C042–C044.
Adverse branch
If one included obligation remains unpaid, branch A is not satisfied.
Missing proof
Order, creditor paid-up confirmations, account balances, certificate and filing receipts.
Workflow 2 — continuing housing mortgage, criteria met
Assumed facts
- Rearrangement includes a qualifying mortgage securing credit used to purchase the consumer’s home.
- Consumer shows financial ability to make future rearranged payments.
- Mortgage has no arrears.
- All other included agreements are settled in full.
Classification
The §71(1)(b) branch may support clearance even though the mortgage continues. C035–C037.
Adverse branch
A home-related loan that is not a qualifying mortgage agreement, or a mortgage not securing purchase/improvement credit, may not fit the branch.
Missing proof
Registered mortgage agreement, rearrangement order, current payment history, affordability evidence and other paid-up letters.
Workflow 3 — continuing housing mortgage with arrears
Assumed facts
- Same general mortgage as Workflow 2.
- Two rearranged mortgage instalments remain in arrears.
Classification
Section 71(1)(b)(ii)’s no-arrears predicate is not met. Clearance is not established merely because every unsecured debt is settled.
Adverse branch
If the account statement is wrong, the arrears entry can be disputed, but the consumer still must prove the statutory clearance criteria.
Missing proof
Mortgage statement, allocation records and creditor confirmation.
Workflow 4 — claimed “other long-term agreement”
Assumed facts
- One long-term vehicle agreement remains.
- Consumer asserts it falls under §71(1)(b)(i)(bb).
- No regulation prescribing that product as an eligible long-term agreement is produced.
Classification
P15 cannot classify the agreement into that branch. The statutory phrase depends on a prescribed category that was not established in the sources read.
Adverse branch
A later operative regulation may identify a product category; an old form or business practice cannot invent it.
Missing proof
Current prescribing regulation and full agreement.
Workflow 5 — debt counsellor refuses the certificate
Assumed facts
- Consumer says all non-mortgage debts are settled and the qualifying mortgage criteria are met.
- Debt counsellor gives written reasons refusing Form 19.
Classification
The consumer may apply to the NCT under §71(3). The Tribunal may order issuance if satisfied that the statutory criteria are met. C040–C041.
Adverse branch
The Tribunal may agree with the counsellor if financial ability, no-arrears status or settlement evidence is insufficient.
Missing proof
Rearrangement order, refusal reasons, paid-up letters, mortgage evidence and current Tribunal procedural compliance.
Workflow 6 — certificate issued but not filed
Assumed facts
- Debt counsellor issues a valid certificate.
- More than seven statutory days pass without filing.
Classification
The consumer may file a certified copy with the NCR and lodge a complaint against the counsellor under §71(4)(b). C042–C043.
Adverse branch
If no certificate was actually issued, the substitute-filing branch does not apply; the §71(3) review route is the relevant starting point.
Missing proof
Certificate, issuance date, delivery evidence and bureau/NCR filing records.
Workflow 7 — unverified disputed listing
Assumed facts
- Consumer files a complete challenge with a primary bureau on Monday, 2 February 2026.
- No public holiday occurs in the following 20-business-day period.
- Bureau cannot obtain credible evidence.
Twenty-business-day calculation
The filing day is excluded under NCA §2(5).
| Business-day count |
Date |
| 1 |
Tuesday, 3 February 2026 |
| 5 |
Monday, 9 February |
| 10 |
Monday, 16 February |
| 15 |
Monday, 23 February |
| 20 |
Monday, 2 March 2026 |
By that date, under the assumed facts, the holder must have taken the §72(3)/regulation 20 steps. If no credible evidence exists, the information must be removed and the required parties informed. C010, C012–C014, C020–C022.
Guideline branch
The 2024 guideline says the challenged information should be masked within five business days after receipt of a complete challenge. That masking period is guidance, not substituted for the binding 20-business-day investigation rule.
Missing proof
Complete challenge, receipt date, supporting documents and bureau evidence.
Workflow 8 — accurate adverse listing followed by settlement
Assumed facts
- Accurate default classification exists.
- Consumer settles the obligation on date S.
- Credit provider receives and records the settlement.
Statutory sequence
- Credit provider submission deadline: within seven days after S.
- Bureau removal deadline: within seven days after its actual receipt R.
The overall process is not automatically S + 14 days, because the bureau’s clock runs from receipt of the credit provider’s information, and actual receipt may occur earlier than the seventh day. C052–C055.
Adverse branch
If only arrears—but not the whole obligation—are paid, regulation 19(10)’s update mechanism may apply instead of full §71A settlement.
Missing proof
Settlement meaning, account ledger, creditor submission and bureau receipt.
Workflow 9 — judgment paid but not rescinded
Assumed facts
- Capital amount of a judgment debt is paid.
- No court has rescinded the judgment.
Classification
The creditor must report the settlement under §71A/regulation 19(11), and the bureau removes or updates the adverse paid-judgment listing within the applicable period. The judgment itself is not judicially rescinded merely because its bureau listing is removed. C052–C059.
Adverse branch
A separate rescission order triggers §71(6), requiring removal of all judgment information.
Missing proof
Judgment, settlement, creditor submission, bureau action and any court order.
Workflow 10 — erroneous debt-review flag
Assumed facts
- Bureau shows a debt-review flag.
- Consumer asserts no Form 17.1, assessment, application, order or agreement ever existed.
Classification
The consumer may challenge the flag under §72. The bureau or source must seek credible evidence and withhold reporting while unresolved.
Adverse branch
If valid debt-review documentation exists, the information may be accurate; removal then depends on clearance, valid withdrawal or another operative status change.
Missing proof
Debt-review application, notices, DHS entry, court/Tribunal order and bureau-source records.
Workflow 11 — prescription assertion not proved
Assumed facts
- Consumer says an old account “must have prescribed.”
- No contract, due date, acknowledgment history, payment history or service record is supplied.
Classification
The assertion can be raised as a dispute, but it does not establish prescription. The reporting source must investigate and provide credible evidence or remove unsupported information.
Adverse branch
If the debt remains legally enforceable or prescription was interrupted, a valid accurate listing may remain subject to the applicable retention rule.
Missing proof
All prescription predicates; P12 remains unreviewed.
Workflow 12 — withdrawal versus clearance
Assumed facts
- Consumer is currently under valid debt review.
- No certificate criteria are met.
- A private company advertises instant “debt review removal.”
Classification
This is not a §71 clearance fact pattern. Any withdrawal or court-status route must be separately established. The private company’s promise does not itself alter bureau records. C051.
Adverse branch
If §71 criteria later become satisfied, the statutory certificate route applies.
Missing proof
Debt-review stage, order, withdrawal authority, counsellor role and actual bureau records.
Workflow 13 — multiple bureaux after successful dispute
Assumed facts
- Primary bureau removes unsupported information.
- It reported that item to two lenders during the previous 20 business days.
- Three other registered bureaux hold corresponding records.
Classification
Regulation 20(3) requires notice to:
- the consumer;
- the two recent recipients; and
- all other registered bureaux.
The consumer does not need a separate merits determination from every bureau merely to trigger that notification duty, assuming the primary bureau removed the item under §72(3)(b). C020–C021.
Missing proof
Recipient list, bureau notices and corresponding removals.
Workflow 14 — adverse label removed, factual payment history remains
Assumed facts
- Default label is removed after settlement under §71A.
- Accurate month-by-month payment history remains within the five-year maximum.
- No separate inaccuracy is alleged.
Classification
Removal of the adverse classification does not necessarily require deletion of the entire factual payment profile. The remaining history must still be accurate, lawfully reportable and within its retention period. C023–C028, C056.
Adverse branch
If the retained history itself is inaccurate or mislabels the account, it may be challenged under §72.
Missing proof
Exact bureau fields, event dates and reporting purpose.
Five conditional time examples
Example A — certificate issuance and filing
Let:
- E = date the §71(1) eligibility event is established;
- I = actual certificate-issuance date.
Statutory sequence:
Issue no later than E + 7 statutory days
File no later than I + 7 statutory days
The Act does not use “business days” in these subsections. P15 does not calculate an exact final instant, holiday adjustment or deemed-receipt rule. DTIC+1
Example B — §71A settlement sequence
Let:
- S = settlement date;
- R = bureau’s actual receipt date.
Credit provider reports by S + 7 statutory days
Bureau removes by R + 7 statutory days
The aggregate is not automatically 14 days from settlement because R is a separate factual event. DTIC
Example C — regulation 20 dispute period
Assumed complete challenge: Monday, 2 February 2026.
Using NCA §2(5):
- exclude trigger day;
- exclude weekends and public holidays;
- include the day of performance.
With no intervening public holiday:
20th business day = Monday, 2 March 2026
This is fictional and does not establish an actual consumer deadline. South African Government
Example D — payment-profile maximum
Assumed payment-profile event: 15 January 2024.
15 January 2024 + 5 years = nominal anniversary 15 January 2029
This illustrates the maximum-period arithmetic only. Earlier mandatory removal, correction, account updates and exact last-instant rules remain separate. South African Government
Example E — adverse-classification maximum
Assumed adverse classification event: 10 June 2025.
10 June 2025 + 1 year = nominal anniversary 10 June 2026
If the obligation is settled and §71A applies before then, the listing must be removed earlier under §71A. South African Government+1
G5. Reviewed P05 D14 disposition
| Reviewed row |
Original reviewed wording |
P15 result |
Status |
| P05 D14 — Credit reporting/clearance |
“Existing reporting/clearance guidance not fee-authority proof.” |
National reporting categories, retention, adverse-listing gates, §72 disputes, §71 clearance, §71A paid-up removal, Form 19/platform procedure and source-version conflicts are now researched. |
Partial substantive completion. No actual report, clearance entitlement, court order, score result, provincial procedure or private remedy is accepted. |
| P06 PDA |
Saved, unreviewed |
No client-money or payment conclusion used. |
Held |
| P10 NCR/NCT enforcement |
Saved, unreviewed |
No sanction, complaint or order conclusion used beyond the statutory cross-reference. |
Held |
| P11 CPA/ECTA patch |
Saved, unreviewed |
No contract/cancellation premise used. |
Held |
| P13 classification |
Saved, unreviewed |
No product classification result used. |
Held |
| P14 prescription correction |
Saved/imported |
No P12 prescription merits adopted. |
Held |
| 2019 debt intervention |
Prior commencement hold |
Pending reporting provisions not used. |
Held |
| Country/A066/A097/A098 |
Unaccepted |
P15 is a national reporting gateway only. |
Held |
Reporting-route comparison
| Mechanism |
Trigger |
Actor with immediate duty |
Core effect |
What it does not establish |
| §71 clearance |
Statutory clearance criteria met |
Debt counsellor |
Issue certificate; file with bureaux/register; remove debt-review records |
Judgment rescission, score increase or new-credit approval |
| §71A paid-up removal |
Settlement of listed adverse/judgment obligation |
Credit provider, then bureau |
Report settlement; remove adverse listing |
Whole payment-profile deletion or judicial rescission |
| §71(6) judgment rescission |
Court rescinds judgment |
Bureau after receiving order |
Remove all judgment information |
Underlying debt validity outside order |
| §72 dispute |
Accuracy challenged |
Bureau/provider/register |
Seek evidence; substantiate or remove; suppress while unresolved |
Automatic debt extinction |
| Regulation 17 expiry |
Maximum retention period reached |
Bureau |
Stop display/use of expired item |
Settlement or invalidity of underlying debt |
| Regulation 19 arrears update |
Arrears underlying adverse item settled |
Reporting source and bureau |
Update account to reflect settlement |
Full account closure or §71 clearance |
| Historical 2014 amnesty |
Information existing at historical effective date / paid judgment |
Bureaux and credit providers |
One-time cleansing and paid-judgment removal |
Current general amnesty for every new listing |
Full source register — C_ZA-P15-S001 onward
All fresh accesses occurred on 26 October 2026 PDT / 27 October 2026 UTC. Exact source-specific clock times are unknown.
| Source ID |
Issuer, title and complete literal HTTPS URL |
Exact provisions and page locators |
Status, commencement and read limits |
| C_ZA-P15-S001 |
dtic, National Credit Act 34 of 2005, dated amended compilation. https://www.thedtic.gov.za/wp-content/uploads/National_Credit_Act34of2005.pdf |
§2(5), zero P13; §70, zero P45–P46; §71, P46–P47; §71A, P47–P49; §72, P49–P50; §73, P50. Original Gazette printed-page mapping not independently preserved for this compilation. |
Fresh integrated body and relevant PDF pages read. Dated to 2019 and displays uncommenced 2019 provisions as pending; not a certified October 2026 consolidation. DTIC+3 |
| S002 |
Parliament/Presidency, National Credit Amendment Act 19 of 2014, GG37665, GoN389, 19 May 2014. https://www.gov.za/sites/default/files/gcis_document/201409/37665gon389.pdf |
Amendment of §71, zero P8–P9 / printed GG pp16–18; insertion of §71A follows in same amending Act. |
Fresh enacted primary body and page images read. Supplies controlling 2014 clearance wording. Commencement established by S003. South African Government+1 |
| S003 |
President, Commencement of National Credit Amendment Act 19 of 2014, Proclamation R.10 of 2015, GG38557, 13 March 2015. https://www.gov.za/sites/default/files/gcis_document/201503/38557reg10382pro10.pdf |
Entire proclamation, zero P0 / printed GG p3. |
Precisely attributable official primary source, freshly reopened in the research chain. Commenced Act 19/2014 on publication; not the 2019 debt-intervention proclamation. |
| S004 |
Minister of Trade and Industry, National Credit Regulations including Affordability Assessment Regulations, GoN R202, GG38557, 13 March 2015. https://www.gov.za/sites/default/files/gcis_document/201503/38557rg10382gon202.pdf |
Effective-date notice zero P0/printed p5; regulation 17 retention table P18–P19 / printed pp23–24; regulations 19(6)–(13) P20–P21 / printed pp24–25. |
Fresh final gazetted body and page images read. Effective on publication. Later amendments not exhaustively excluded; contains apparent “Prescription Act 68 of 1998” drafting error. South African Government+2 |
| S005 |
Minister, National Credit Regulations, GoN R489, GG28864, 31 May 2006. https://www.gov.za/sites/default/files/gcis_document/201409/28864.pdf |
Original regulation 17 zero P14–P15 / printed pp17–18; regulations 18–20 P16–P18 / printed pp19–21; regulation 27 zero P24 / printed p27. |
Fresh original final regulations and relevant pages read. Regulation 17 was later replaced and regulation 19 supplemented; regulation 27’s older clearance wording conflicts with amended §71 and is not treated as controlling over the Act. South African Government+2 |
| S006 |
NCR, Guideline on the Filing of Clearance Certificates (Form 19) via the CBA Debt Counselling Platform, Guideline 001/2026, February 2026. https://www.ncr.org.za/documents/Guidelines/Guideline%20February%202026.pdf |
Cover zero P0; background/purpose P1; platform process P1–P3. Internal printed pages 1–4. |
Fresh official regulator guidance read. One P1 screenshot attempt produced a verification page; parsed official PDF text and P2 image were available. Procedural guidance, not an amendment to §71 eligibility. NCR+1 |
| S007 |
NCR, Guidelines for the Submission of Complaints Relating to Disputed Consumer Credit Information, Guideline 005/2024, December 2024. https://www.ncr.org.za/phocadownload/GUIDELINES%20FOR%20THE%20SUBMISSION%20OF%20COMPLAINTS%20RELATING%20TO%20DISPUTED%20CONSUMER%20CREDIT%20INFORMATION1.pdf |
Statutory framework zero P1/printed p2; bureau challenge procedure P2–P3/printed pp3–4. |
Fresh official guideline body and page images read. Five-business-day masking is guidance; 20-business-day resolution derives from regulation 20. NCR+1 |
| S008 |
NCR, Form 19 — Clearance Certificate Issued in Terms of Section 71. https://www.ncr.org.za/index.php/act/list-of-forms?download=450:form-19-clearance-certificate-issued |
Entire one-page form, zero P0; printed page label unverified. |
Fresh official form body read. Retains older all-obligations wording and an old subsection reference; not treated as overriding amended §71. NCR+1 |
| S009 |
NCR/Government Gazette, National Credit Amendment Regulations and Tribunal Rules/Forms, combined March 2015 publication. https://ncr.org.za/documents/pages/NCA-amendment-Regulations-March-20151.pdf |
Form TI.71(3), around zero P73–P76 / printed pp73–76; Tribunal filing table item for §71(3), zero P207–P209 / printed pp207–209. |
Fresh relevant form/table text read. Used for generic evidence requirements and route identity; not a complete current Tribunal-rules certification or current filing deadline. NCR+1 |
| S010 |
NCR, Circular 2 of 2025 — “Debt Review Removal”, March 2025. https://www.ncr.org.za/documents/Circulars/Circular%202%20of%202025%20-%20Debt%20Review%20Removal%20(003)%20(002).pdf |
Entire circular, zero P0–P1 / internal pp1–2. |
Fresh official circular read. Used only to distinguish commercial “removal” claims from statutory clearance/withdrawal; no fee statements adopted. NCR+1 |
| S011 |
Minister, Removal of Adverse Consumer Credit Information Relating to Paid-Up Judgments, GoN R144, GG37386, 26 February 2014. https://www.gov.za/sites/default/files/gcis_document/201409/37386rg10136gon144.pdf |
Definitions zero P1/printed p4; removal duties P2–P4 / printed pp5–7; effective-date provision P7/printed p10. |
Fresh historical final regulation and relevant pages read. One-time adverse-information removal plus ongoing paid-judgment provisions; not a current universal amnesty. South African Government+2 |
| S012 |
Parliament/Justice, Protection of Personal Information Act 4 of 2013, amended compilation. https://www.justice.gov.za/legislation/acts/2013-004.pdf |
§3 interaction, zero P5; §14 retention, P8–P9; §16 information quality, P9. Original Gazette printed-page mapping not separately recorded. |
Fresh limited crossover body read. Used only for sector-law interaction, retention and accuracy principles; no full POPIA module or 2026 comprehensive privacy currentness claim. Justice+1 |
| S013 |
dtic, Briefing to Portfolio Committee on Small Business Development: Areas of Policy Overlaps, 12 November 2025. https://www.thedtic.gov.za/wp-content/uploads/re-Revised-Part-A-Regs.pdf |
Withdrawn-draft identification zero P1–P2; credit-information/MSME explanation P5–P7. |
Fresh official explanatory briefing read. Establishes withdrawal of the August 2025 draft in entirety; not legislation or current reporting rule. DTIC+1 |
Complete atomic claim/evidence register — C_ZA-P15-C001 onward
All claims are national and bounded. A066, A097 and A098 remain unaccepted.
| Claim ID |
Exact actor, predicate, duty, time and effect |
Primary source/pinpoint |
Exception or remaining hold |
| C_ZA-P15-C001 |
Consumer credit information includes credit, payment, default, rearrangement, enforcement, termination, financial, employment, business and identity information. |
S001 §70(1), zero P45. |
Exact field and lawful purpose matter. |
| C002 |
Credit bureau must accept proper filings from credit providers. |
S001 §70(2)(a). |
Does not validate inaccurate data. |
| C003 |
Bureau must accept consumer correction/challenge submissions without charge where Act requires. |
S001 §70(2)(b). |
Prescribed process applies. |
| C004 |
Bureau must verify accuracy of information. |
S001 §70(2)(c). |
Source evidence and dispute process matter. |
| C005 |
Bureau may retain information only for prescribed period. |
S001 §70(2)(d). |
Earlier removal rules can apply. |
| C006 |
Bureau must promptly expunge prohibited or mandatory-removal information. |
S001 §70(2)(e). |
Exact removal trigger required. |
| C007 |
Bureau must not knowingly or negligently issue inaccurate information. |
S001 §70(2)(g). |
Actual state of knowledge/evidence held. |
| C008 |
Person has one free inspection in each 12-month period. |
S001 §72(1)(b)(i)(aa), P49. |
Additional free routes separately listed. |
| C009 |
Successful challenger has one free follow-up inspection within a reasonable period. |
§72(1)(b)(i)(cc). |
“Reasonable” is fact-sensitive. |
| C010 |
Accuracy challenge and investigation must be available without charge. |
§72(1)(c). |
Does not guarantee removal. |
| C011 |
Reporter of incorrect information may owe correction costs under §72(1)(d). |
S001 §72(1)(d). |
No damages quantum or automatic award determined. |
| C012 |
Holder must seek credible evidence supporting challenged information. |
§72(3). |
Complete challenge and identity proof may be required. |
| C013 |
If no credible evidence is found, holder must remove information and all record of it. |
§72(3)(b). |
Tribunal limitation under §72(6). |
| C014 |
Challenged information may not be reported while unresolved. |
§72(5). |
Resolution may support reinstatement if accurate. |
| C015 |
After receiving supporting evidence, challenger has 20 business days to approach NCR under §72(4). |
§72(4). |
Separate from bureau’s 20-day investigation period. |
| C016 |
Tribunal may limit obligations for frivolous, unfounded, unreasonable or vexatious requests. |
§72(6). |
Tribunal order required. |
| C017 |
Reporting sources must take reasonable steps for accuracy, currency, relevance, completeness, validity and nonduplication. |
S005 reg19(3), zero P18/printed p21. |
Actual source conduct unknown. |
| C018 |
At least 20 business days’ notice precedes specified adverse behaviour/enforcement reporting. |
S005 reg19(4), zero P18/printed p21. |
Not every neutral entry. |
| C019 |
Adverse information requires at least three consecutive unpaid billing cycles. |
S004 reg19(7), zero P20/printed p24. |
Other category predicates remain. |
| C020 |
Adverse info may not be submitted if arrears settle during notice or liability is timely disputed. |
S004 reg19(9), P20/printed p24. |
Dispute need not ultimately succeed. |
| C021 |
Reg20 gives 20 business days after filing challenge to perform §72(3) steps. |
S005 reg20(2), P18/printed p21. |
Complete filing/receipt facts matter. |
| C022 |
After removal, bureau informs consumer, recent recipients and all registered bureaux. |
S005 reg20(3). |
Applies to removal under §72(3)(b). |
| C023 |
Factual payment profile has five-year maximum. |
S004 reg17 item3, P18/printed p23. |
Earlier correction/removal possible. |
| C024 |
Adverse behaviour/enforcement classifications have one-year maximum or earlier §71A period. |
S004 reg17 items4–5, P19/printed p24. |
Settlement can trigger earlier removal. |
| C025 |
Debt-restructuring information remains during §71 period or until clearance. |
S004 reg17 item6. |
Valid withdrawal/correction may be separate. |
| C026 |
Civil judgments remain for earlier of five years or listed earlier-removal events. |
S004 reg17 item7. |
Maintenance judgments differ. |
| C027 |
Enquiries, complaints, sequestration, rehabilitation and administration orders have separate maximums. |
S004 reg17 table. |
Category-specific triggers. |
| C028 |
Retention periods are maxima, not mandatory minimum display periods. |
§70(2)(d), reg17 and §§71/71A synthesis. |
Other lawful retention duties may exist. |
| C029 |
2014 amnesty was historical one-time removal plus paid-judgment process. |
S011 regs2–4. |
Not current blanket deletion rule. |
| C030 |
August 2025 credit-information draft was withdrawn in entirety. |
S013 P1, P5–P7. |
No current effect. |
| C031 |
POPIA coexists with more extensive lawful-processing conditions in sector law. |
S012 §3(2)(b). |
Full privacy module deferred. |
| C032 |
POPIA generally limits retention to lawful necessity and requires deletion/de-identification or restriction after basis ends. |
S012 §14. |
NCA statutory retention can supply legal basis. |
| C033 |
POPIA requires reasonable accuracy, completeness and updating. |
S012 §16. |
NCA dispute route remains specific. |
| C034 |
§71 clearance branch A requires satisfaction of all included obligations. |
S001 §71(1)(a); S002 amendment. |
Actual balances/order held. |
| C035 |
§71 branch B permits qualifying continuing mortgage/other prescribed long-term agreement. |
§71(1)(b)(i). |
“Other prescribed” category not established. |
| C036 |
Continuing agreement must have no arrears. |
§71(1)(b)(ii). |
Account accuracy held. |
| C037 |
All other included agreements must be settled in full. |
§71(1)(b)(iii). |
Included-agreement list required. |
| C038 |
No operative additional “other long-term agreement” class was established. |
Bounded search of S001–S006. |
Not proof none exists. |
| C039 |
Debt counsellor must issue certificate within seven days after eligibility event. |
§71(1). |
Statute says days, not business days. |
| C040 |
Consumer may seek NCT review if counsellor refuses or fails to issue. |
§71(3). |
Current procedural compliance required. |
| C041 |
TI.71(3) material identifies evidence categories for review. |
S009 form/table. |
No complete current filing deadline certified. |
| C042 |
Debt counsellor files certificate within seven days after issuance. |
§71(4)(a). |
Actual delivery/receipt proof needed. |
| C043 |
Consumer may file certified copy with NCR and complain if counsellor fails to file. |
§71(4)(b). |
Certificate must already exist. |
| C044 |
Clearance receipt requires removal of debt-review fact, associated defaults and rearranged-agreement records. |
§71(5). |
Not every unrelated item. |
| C045 |
Clearance certificate is not itself judgment rescission. |
§§71(5)–(6). |
Separate court order required for rescission branch. |
| C046 |
Court rescission order requires bureau to expunge all judgment information. |
§71(6). |
Actual court order required. |
| C047 |
Guideline 001/2026 establishes CBA platform filing process. |
S006 P1–P3. |
Guidance does not amend eligibility. |
| C048 |
2026 platform guidance cannot narrow the mortgage branch. |
§71 versus S006 source hierarchy. |
Actual system-field treatment unknown. |
| C049 |
Public Form19 retains older all-obligations wording. |
S008 P0. |
Form cannot override amended Act. |
| C050 |
Original regulation27 retains older all-debts wording. |
S005 reg27, zero P24/printed p27. |
Later Act controls; harmonisation gap remains. |
| C051 |
Withdrawal/removal marketing is distinct from statutory clearance. |
S010 circular. |
Full withdrawal module deferred. |
| C052 |
Credit provider reports §71A settlement within seven days. |
§71A(1). |
Obligation must fit listed categories. |
| C053 |
Bureau removes qualifying adverse listing within seven days after receipt. |
§71A(2). |
Receipt date is separate factual trigger. |
| C054 |
Consumer may complain if credit provider fails to report settlement. |
§71A(3). |
Broader complaint process not adopted. |
| C055 |
§71A defines adverse behaviour and enforcement classifications. |
§71A(4). |
Examples do not encompass all report fields. |
| C056 |
§71A removal of adverse listing does not necessarily delete entire factual payment profile. |
§71A plus reg17 item3. |
Remaining history must be accurate/lawful. |
| C057 |
Settled arrears must be reported in next data submission and record updated within seven days after notice. |
S004 reg19(10). |
Not necessarily whole obligation settlement. |
| C058 |
Paid judgment capital must be reported within §71A period and record updated within seven days after notice. |
S004 reg19(11). |
Does not itself rescind judgment. |
| C059 |
Paid judgment listing removal and judicial rescission are distinct. |
§§71(6),71A; reg19(11). |
Actual order/payment proof required. |
| C060 |
Reporting ban applies only if debt is actually prescribed. |
S005 reg19(5); S004 reg19(6). |
Prescription merits held. |
| C061 |
2015 reg19(6) contains apparent “Act 68 of 1998” drafting error, unlike original 1969 reference. |
S004/S005. |
P15 does not resolve legal correction. |
| C062 |
A dispute does not itself invalidate or extinguish the underlying debt. |
§§72(3),(5) source/effect distinction. |
Separate contract/prescription law. |
| C063 |
Credible evidence can support retention after challenge. |
§72(3)(a). |
Consumer may escalate under §72(4). |
| C064 |
No credible evidence requires removal. |
§72(3)(b). |
Tribunal §72(6) exception. |
| C065 |
Free report access does not guarantee score change. |
§72(1)(b) and scope inference. |
Scoring models/private decisions separate. |
| C066 |
Removal/correction does not guarantee new-credit approval. |
Statutory-purpose boundary. |
Credit assessment separate. |
| C067 |
Pending 2019 reporting/debt-intervention provisions are not used. |
S001 pending annotations; prior holds. |
Commencement unresolved. |
| C068 |
2015 final regulations are latest final retention body established here, not certified as unchanged forever. |
S004 plus bounded search and S013. |
Later instrument could exist. |
| C069 |
No actual credit report, bureau database or account was accessed. |
Research-method fact. |
Private facts wholly unknown. |
| C070 |
National NCA sources do not complete provincial/local procedures. |
Scope limit. |
Nine territorial rows remain open. |
| C071 |
P05 D14 moves to partial national substantive coverage. |
C001–C070. |
Actual entitlement/outcome held. |
| C072 |
A066/A097/A098 and whole-country acceptance remain held. |
Scope/provenance limitation. |
Separate review required. |
Complete granular coverage register
G1 — Reporting perimeter, retention and disputes: 28 rows
| Row |
Subissue |
Status |
Finding/claims |
Missing fact or exact next action |
| G1-01 |
Current NCA source chain |
partial-currentness |
C001–C007, C067–C068 |
Complete later-amendment citator if operational publication |
| G1-02 |
§70 information categories |
answered |
C001 |
Actual field/purpose |
| G1-03 |
Bureau acceptance of filings |
answered |
C002 |
Submission validity |
| G1-04 |
Free correction/challenge intake |
answered |
C003,C010 |
Complete challenge |
| G1-05 |
Accuracy verification duty |
answered |
C004,C017 |
Evidence |
| G1-06 |
Retention-limited duty |
answered |
C005,C028 |
Correct category/date |
| G1-07 |
Mandatory expungement |
answered conditionally |
C006 |
Removal trigger |
| G1-08 |
Inaccurate reporting prohibition |
answered |
C007 |
Knowledge/negligence facts |
| G1-09 |
One free annual report |
answered |
C008 |
Actual request |
| G1-10 |
Post-correction free inspection |
answered |
C009 |
Reasonable period |
| G1-11 |
Correction-cost compensation |
partial |
C011 |
Actual costs/liability route |
| G1-12 |
20-business-day adverse notice |
answered |
C018 |
Category/notice receipt |
| G1-13 |
Three billing-cycle gate |
answered |
C019 |
Billing history |
| G1-14 |
Settlement/dispute pre-listing bar |
answered conditionally |
C020 |
Timely settlement/dispute |
| G1-15 |
Bureau dispute period |
answered |
C021 |
Complete filing date |
| G1-16 |
Cross-bureau notification after removal |
answered |
C022 |
Actual recipient list |
| G1-17 |
Five-year payment profile |
answered as maximum |
C023 |
Event date/earlier removal |
| G1-18 |
One-year adverse classifications |
answered as maximum |
C024 |
§71A earlier event |
| G1-19 |
Debt-restructuring retention |
answered |
C025 |
Clearance/withdrawal facts |
| G1-20 |
Civil-judgment retention |
answered |
C026 |
Payment/rescission/abandonment |
| G1-21 |
Other retention categories |
answered |
C027 |
Specific order/status |
| G1-22 |
Historical amnesty |
answered historically |
C029 |
Not current universal rule |
| G1-23 |
2025 withdrawn draft |
answered as non-operative |
C030 |
No current effect |
| G1-24 |
POPIA interaction |
partial crossover |
C031–C033 |
Full privacy module |
| G1-25 |
Prescription-reporting ban |
partial |
C060–C061 |
Actual prescription and drafting resolution |
| G1-26 |
Challenge suppression |
answered |
C014 |
Resolution evidence |
| G1-27 |
NCR escalation after evidence |
answered at gateway level |
C015 |
Actual complaint procedure held |
| G1-28 |
Score/new-credit consequences |
answered negatively |
C065–C066 |
Private scoring/assessment |
G2 — Debt-review clearance: 22 rows
| Row |
Subissue |
Status |
Finding/claims |
Missing fact or next action |
| G2-01 |
All-obligations branch |
answered |
C034 |
Complete account proof |
| G2-02 |
Continuing mortgage branch |
answered conditionally |
C035 |
Agreement/order/property purpose |
| G2-03 |
Other prescribed long-term agreement |
unresolved |
C038 |
Current prescribing regulation |
| G2-04 |
Financial ability |
partial |
C035,C041 |
Current proof and calculation |
| G2-05 |
No-arrears predicate |
answered |
C036 |
Accurate statement |
| G2-06 |
Other debts settled in full |
answered |
C037 |
Included-debt list |
| G2-07 |
Seven-day issuance |
answered |
C039 |
Eligibility event date |
| G2-08 |
Calendar/business-day classification |
answered textually |
C039 |
Exact computation held |
| G2-09 |
Refusal/failure review |
answered |
C040 |
Current procedural compliance |
| G2-10 |
TI.71(3) evidence package |
partial |
C041 |
Current complete rules/forms |
| G2-11 |
NCT filing deadline |
unresolved |
C041 |
Current Tribunal rule |
| G2-12 |
Seven-day bureau filing |
answered |
C042 |
Issuance/receipt evidence |
| G2-13 |
Consumer substitute filing |
answered |
C043 |
Valid certificate |
| G2-14 |
Clearance-removal categories |
answered |
C044 |
Actual bureau action |
| G2-15 |
Clearance versus judgment rescission |
answered boundary |
C045–C046 |
Court order |
| G2-16 |
2026 platform |
answered procedurally |
C047 |
Actual login/submission |
| G2-17 |
Platform versus eligibility |
answered boundary |
C048 |
No narrowing |
| G2-18 |
Form19 wording conflict |
answered as source conflict |
C049 |
Updated form needed |
| G2-19 |
Regulation27 conflict |
answered as source conflict |
C050 |
Harmonised regulation needed |
| G2-20 |
Withdrawal versus clearance |
answered boundary |
C051 |
Full withdrawal law deferred |
| G2-21 |
Debt-review order removal |
partial |
C044–C045 |
Actual order/status |
| G2-22 |
2019 intervention reporting |
excluded_with_reason |
C067 |
Commencement hold |
G3 — Paid-up removal and adverse branches: 22 rows
| Row |
Subissue |
Status |
Finding/claims |
Missing fact or next action |
| G3-01 |
§71A credit-provider duty |
answered |
C052 |
Settlement proof |
| G3-02 |
§71A bureau duty |
answered |
C053 |
Receipt proof |
| G3-03 |
Failure-to-report complaint |
answered at gateway level |
C054 |
P10 process unreviewed |
| G3-04 |
Adverse-behaviour definition |
answered |
C055 |
Exact field |
| G3-05 |
Enforcement-classification definition |
answered |
C055 |
Exact field |
| G3-06 |
Payment-profile adverse listing |
answered boundary |
C052,C056 |
Separate factual history |
| G3-07 |
Whole-profile deletion |
answered negatively |
C056 |
Accuracy/retention still apply |
| G3-08 |
Paid arrears update |
answered |
C057 |
Next-submission timing |
| G3-09 |
Paid judgment update |
answered |
C058 |
Settlement and notice |
| G3-10 |
Paid judgment versus rescission |
answered |
C059 |
Court order separate |
| G3-11 |
Credible evidence branch |
answered |
C063 |
Evidence sufficiency |
| G3-12 |
No-evidence branch |
answered |
C064 |
§72(6) exception |
| G3-13 |
Erroneous debt-review flag |
answered as dispute route |
C010–C014 |
Actual source documents |
| G3-14 |
Accurate debt-review flag |
answered boundary |
C044,C051,C062 |
Clearance/withdrawal |
| G3-15 |
Prescription assertion |
partial |
C060–C061 |
Actual prescription |
| G3-16 |
Multiple bureaux |
answered |
C022 |
Notice compliance |
| G3-17 |
Historical paid-judgment removal |
answered historically |
C029 |
Modern route separate |
| G3-18 |
Adverse listing and score |
answered negatively |
C065 |
Scoring model separate |
| G3-19 |
Removal and new credit |
answered negatively |
C066 |
New assessment |
| G3-20 |
Debt validity after removal |
excluded_with_reason |
C062 |
Contract/enforcement module |
| G3-21 |
Compensation for correction costs |
partial |
C011 |
Claim/quantum route |
| G3-22 |
POPIA correction/removal |
partial crossover |
C031–C033 |
Information Regulator module |
G4 — Fictional workflows and timing examples: 14 rows
| Row |
Workflow |
Status |
Claims |
Missing facts |
| G4-01 |
All unsecured debts settled |
answered conditionally |
C034,C039,C042–C044 |
Paid-up proof/order |
| G4-02 |
Continuing housing mortgage met |
answered conditionally |
C035–C037 |
Mortgage/ability/arrears |
| G4-03 |
Mortgage arrears remain |
answered adverse branch |
C036 |
Accurate account |
| G4-04 |
Other long-term agreement claimed |
unresolved |
C038 |
Prescribing regulation |
| G4-05 |
Counsellor refuses certificate |
answered route |
C040–C041 |
Tribunal procedure/evidence |
| G4-06 |
Certificate not filed |
answered route |
C042–C043 |
Issuance/file evidence |
| G4-07 |
Unsupported disputed listing |
answered conditionally |
C012–C014,C020–C022 |
Complete challenge/evidence |
| G4-08 |
Accurate adverse listing paid |
answered conditionally |
C052–C057 |
Settlement/receipt |
| G4-09 |
Judgment paid/not rescinded |
answered boundary |
C058–C059 |
Court order |
| G4-10 |
Erroneous debt-review flag |
answered conditionally |
C010–C014 |
Source records |
| G4-11 |
Prescription assertion unproved |
partial |
C060–C064 |
Prescription facts |
| G4-12 |
Withdrawal versus clearance |
answered boundary |
C051 |
Withdrawal law |
| G4-13 |
Multiple bureaux |
answered |
C022 |
Notices/removals |
| G4-14 |
Adverse label removed/history remains |
answered boundary |
C023–C028,C056 |
Exact report fields |
G5 — Reviewed gap and scope: 8 rows
| Row |
Matter |
Status |
Finding/claims |
Exact next action |
| G5-01 |
P05 D14 |
partial substantive completion |
C001–C071 |
Apply to actual records separately |
| G5-02 |
Full current NCA consolidation |
partial-currentness |
C067–C068 |
Complete later-amendment review |
| G5-03 |
Current reporting regulations |
partial-currentness |
C068 |
Search any post-2015 final amendments |
| G5-04 |
P06/P10/P11/P13 |
excluded as premises |
Provenance hold |
Separate review |
| G5-05 |
P14/P12 prescription merits |
excluded as premise |
C060–C061 |
Separate review |
| G5-06 |
No private data |
answered |
C069 |
None |
| G5-07 |
Province/local scope |
unresolved |
C070 |
Territorial rows below |
| G5-08 |
A066/A097/A098/country |
held |
C072 |
Separate complete review |
Explicitly deferred legal families
| Row |
Deferred family |
Status |
Exact retained question |
| D01 |
Current debt-counsellor fees and fee conditions |
excluded_with_reason |
Preserve P05/P07/P09 holds |
| D02 |
Private CPA/ECTA service contract |
excluded_with_reason |
P08/P11 not adopted |
| D03 |
PDA/client money/payment distribution |
excluded_with_reason |
P06 unreviewed |
| D04 |
Prescription merits |
excluded_with_reason |
P12/P14 merits not adopted |
| D05 |
NCR/NCT complaint and enforcement |
excluded_with_reason |
P10 unreviewed |
| D06 |
NCA agreement classification |
excluded_with_reason |
P13 unreviewed |
| D07 |
Debt-counsellor registration and provider authority |
excluded_with_reason |
Separate permission module |
| D08 |
Full debt-review eligibility and over-indebtedness |
excluded_with_reason |
Clearance assumes valid rearrangement |
| D09 |
Debt-review withdrawal/termination |
excluded_with_reason |
Separate current procedure |
| D10 |
Court-order validity/rescission |
excluded_with_reason |
Only reporting triggers mapped |
| D11 |
Mortgage/security enforcement |
excluded_with_reason |
Clearance does not decide enforcement |
| D12 |
Judgment enforcement and rescission procedure |
excluded_with_reason |
Court procedure separate |
| D13 |
Credit-score methodology |
excluded_with_reason |
Bureau models/private assessments |
| D14 |
New-credit approval/affordability |
excluded_with_reason |
Removal does not guarantee approval |
| D15 |
Full POPIA/privacy rights |
excluded_with_reason |
Only necessary crossover addressed |
| D16 |
Information Regulator process |
excluded_with_reason |
Separate privacy enforcement |
| D17 |
Private damages/refunds |
excluded_with_reason |
§72 correction-cost right only bounded |
| D18 |
Insolvency/sequestration/rehabilitation |
excluded_with_reason |
Retention row only, full law held |
| D19 |
Administration-order merits |
excluded_with_reason |
Reporting category only |
| D20 |
Tax/public/special debts |
excluded_with_reason |
Separate reporting/product rules |
| D21 |
Foreign bureau data and cross-border processing |
excluded_with_reason |
A098 held |
| D22 |
Foreign law/jurisdiction/recognition |
excluded_with_reason |
Separate pass |
| D23 |
Tribal/customary/community credit |
excluded_with_reason |
No customary-law analysis |
| D24 |
Complete current Tribunal procedural rules |
excluded_with_reason |
§71(3) procedure not fully certified |
| D25 |
2019 debt intervention |
excluded_with_reason |
Pending provisions not used |
| D26 |
Whole-country/A066/A097/A098 acceptance |
excluded_with_reason |
No acceptance from P15 |
Provincial and local register
The NCA reporting rules are national, but P15 did not examine province-specific consumer courts, civil procedure, local court rescission practice, service rules, provincial consumer offices or local remedies.
| Row |
Province |
Status |
Exact remaining question |
| T01 |
Eastern Cape |
unresolved |
What provincial/court procedure applies to a local reporting, rescission or review dispute? |
| T02 |
Free State |
unresolved |
Same forum, procedure and remedy inquiry |
| T03 |
Gauteng |
unresolved |
National NCR/bureau rules do not complete every Gauteng court or local procedure |
| T04 |
KwaZulu-Natal |
unresolved |
No provincial/local body read |
| T05 |
Limpopo |
unresolved |
No provincial/local body read |
| T06 |
Mpumalanga |
unresolved |
No provincial/local body read |
| T07 |
Northern Cape |
unresolved |
No provincial/local body read |
| T08 |
North West |
unresolved |
No provincial/local body read |
| T09 |
Western Cape |
unresolved |
No provincial/local body read |
Evidence-backed article, checklist and conditional-tool opportunities
| Candidate |
Supported function |
Mandatory limitation |
| Credit-record route classifier |
Distinguish §71 clearance, §71A paid-up removal, §72 dispute, rescission and retention expiry |
Not an entitlement or score predictor |
| Form 19 eligibility checklist |
All-paid branch versus continuing-mortgage branch |
Must flag outdated Form19/reg27 wording |
| Clearance evidence packet |
Order, included debts, paid-up letters, mortgage statements, arrears, financial ability and filing proof |
Not a substitute for counsellor/NCT decision |
| Retention-period calculator |
Categorise payment profile, adverse classification, judgment, enquiry or debt restructuring |
Must allow earlier mandatory removal |
| Bureau-dispute timeline tool |
Complete-challenge date, masking guidance, 20-business-day investigation and evidence escalation |
No exact deadline without receipt/holiday facts |
| Paid-judgment explainer |
Separate payment update, adverse-listing removal and court rescission |
Do not claim payment rescinds judgment |
| Debt-review flag audit |
Compare source documentation with bureau status |
No database access or automatic removal |
| Multiple-bureau correction checklist |
Track primary bureau, recent recipients and all bureaux |
Must distinguish challenge removal from §71 filing |
| Reporting-source currentness card |
Show 2006 rule, 2014 amendment, 2015 final regulations, 2024/2026 guidance |
Guidance is not legislation |
| Score-warning panel |
Explain that removal does not guarantee a score or credit approval |
No invented score movement |
Search and read audit
Official repositories used:
- dtic and South African Government for the NCA, 2014 amendment and final regulations;
- NCR for Form 19, the 2026 clearance-filing guideline, 2024 disputed-information guideline and 2025 removal circular;
- Justice for POPIA;
- dtic for the 2025 withdrawn-draft briefing.
Representative bounded searches included:
- site:gov.za National Credit Act section 71 clearance certificate 71A
- site:ncr.org.za Form 19 clearance certificate 2026
- site:gov.za National Credit Regulations retention periods credit bureau 2015
- site:ncr.org.za disputed consumer credit information guideline 2024
- site:gov.za paid up judgments credit information regulations
- site:thedtic.gov.za withdrawn National Credit Regulations credit information 2025
Material limits:
- The dtic NCA compilation is not a certified October 2026 consolidation and includes pending 2019 text.
- No complete post-2015 Gazette sweep was available; P15 does not claim that no later final reporting amendment exists.
- The 2025 draft was withdrawn and is not used as law.
- Public Form 19 and regulation 27 are not harmonised with the amended §71 continuing-mortgage branch.
- The current Tribunal rules governing a §71(3) review were not exhaustively re-certified.
- No credit report, bureau database, creditor ledger, mortgage statement, court order, DHS record or private file was accessed.
- No named consumer, provider, bureau, counsellor, creditor, borrower, company, property, licence, case or docket was searched.
- No complaint, contact, filing, application, record request, payment, account action, site change or publication occurred.
- Failed or incomplete source retrieval is not treated as proof that no rule exists.
Researcher self-check and displayed counts
| Deliverable |
Actual displayed count |
| P15 source-register rows |
13 |
| P15 atomic claims |
72 |
| G1 core coverage rows |
28 |
| G2 core coverage rows |
22 |
| G3 core coverage rows |
22 |
| G4 workflow rows |
14 |
| G5 scope/reconciliation rows |
8 |
| Total core coverage rows |
94 |
| Explicit deferred-family rows |
26 |
| Provincial rows |
9 |
| Total coverage rows |
129 |
| Fictional workflows |
14 |
| Conditional time examples |
5 |
| Reviewed-gap crosswalk rows |
8 |
| Reporting-route comparison rows |
7 |
| New actual score, credit, clearance or deletion outcomes |
0 |
Consistency self-check
- §71 clearance, §71A paid-up removal, §72 dispute and ordinary retention expiry are kept distinct.
- Clearance is not treated as judgment rescission.
- Paid judgment removal is not treated as rescission.
- A dispute does not erase an accurate debt automatically.
- A prescription assertion is not treated as proved prescription.
- Adverse-label removal is not equated with deletion of the entire payment profile.
- Five-year and one-year periods are treated as maxima subject to earlier removal.
- The mortgage clearance branch is preserved.
- Old Form19/regulation27 language is not allowed to narrow the amended Act.
- No “other long-term agreement” category is invented.
- Statutory “days” are not converted to business days.
- The two seven-day §71A clocks are kept tied to separate events.
- The 2026 platform guideline is treated as procedure, not eligibility law.
- The five-business-day dispute masking target is treated as guidance.
- The 20-business-day dispute investigation comes from regulation 20.
- No score increase, credit approval or debt forgiveness is promised.
- P06, P10, P11 and P13 are not adopted.
- No province, locality, A066, A097, A098 or country component is accepted.
Exact next primary-source question
For a specified consumer record, what exact source submitted each disputed field; what category and event date controls its retention period; is the item subject to §71 clearance, §71A settlement removal, §71(6) rescission removal or §72 accuracy challenge; and what documentary evidence proves the relevant payment, order, arrears status, mortgage eligibility, bureau receipt and cross-bureau correction?
Final P15 disposition: P05 D14 moves from wholly deferred to partial substantive national coverage. The national NCA reporting, retention, clearance, paid-up-removal and accuracy-dispute gateway is established. Every actual record, clearance entitlement, bureau response, score outcome, court remedy, provincial/local procedure, foreign issue and A066/A097/A098 acceptance remains held.
END C_ZA PASS-15