{"meta":{"key":"c_za--pass-01","task":"C_ZA","title":"CZA South Africa","parent_title":"South Africa consumer debt and resolution","edition":"pass-01","path":"/research/c_za--pass-01/","kind":"split_pass","category":"international","role":"country","area_numbers":[97,98],"groups":["global"],"date":"2026-10-26","tables":21,"claims":57,"sources":37,"review_status":"scoped_review_with_remaining_primary_currentness_contract_payment_professional_territorial_holds","review_complete":true,"sha256":"c164b58644ff73b173835b76d84fec475ab9bfe0021d454bca802f99231431c1","headings":["Independent provider-perimeter and authorisation gateway","1. Principal findings","1.1 South Africa has distinct legal categories that must not be combined","1.2 Debt-review coverage cannot be presumed for every debt","1.3 Publication holds already established","A–E. Detailed findings and decision rules","1. Identify the service before identifying the licence","2. Debt and debtor classification comes first","3. The statutory route is different from a private workout","4. Actor and claimed-exception matrix","5. Which authority controls which capacity?","6. Special financial and competence conditions actually read","7. Currentness and enactment checkpoints","8. Two recomputed statutory-category cost examples","E. Worked classification and capacity scenarios","Scenario 1 — A debtor-paid firm offers “debt review”","Scenario 2 — “We are a charity, and our employee is qualified”","Scenario 3 — Debtor advocate, creditor collector, and debt purchaser","Scenario 4 — A foreign call-centre advises South African debtors remotely","Scenario 5 — A natural person signs for a business loan or guarantees company debt","Scenario 6 — Private advice versus an appointed statutory office","Two quantitative permission-cost/safeguard checks — with limits","D. Public, read-only verification sequence","Source register — C_ZA-P01-S001 onward","National Credit Act and NCR materials","Debt collection, legal practice and related professional authority","Payment systems, court appointments, corporate rescue and currentness materials","Discovery, obsolete comparisons and regulator-specific records","Atomic claim register — A097/A098 handoff identifiers","Core activity, agreement and authorisation claims","Temporal, exceptional, institutional and verification claims","F. Granular coverage and gap register","A. Activity and agreement perimeter","B. Actor, exemption, remuneration and capacity matrix","C. Authorising/supervising body, financial capacity, nexus and cost","D. Read-only verification, documents and consequences","E. Statutory-solution boundary and worked examples","F. Explicitly deferred subjects — no substantive acceptance","Geographic register — all nine provinces","Research process and self-check","Official-source search and read bounds","Arithmetic self-check","Material questions generated for the next specialist passes","Evidence-grounded HomeLoanWiki/SettleADebt opportunities","Publication and operational holds","Researcher self-check and handoff disposition"],"generation_provenance":{"actual_route":"regular_chat_adaptive_models","actual_model":"GPT-6","actual_mode":"Extra High","provenance_limit":"Actual documented capture labels only; missing labels remain unknown. No preferred setting is inferred as actual execution."},"public_id":"C_ZA/pass-01","facets":{"geography":["international","c_za"],"debt_type":[],"stage":[],"subject":["definitions-classification","provider-licensing"]},"scope":"Independent South African provider perimeter/authorisation gateway only","pending_corrections":0},"markdown":"# C_ZA PASS-01 — South Africa\n\n## Independent provider-perimeter and authorisation gateway\n\nFocused research Acceptance held — A097/A098\n\nResearch baseline: 22 October 2026, America/Los_Angeles\nActual verification: 26 October 2026 (Pacific and UTC); 27 October 2026 in South Africa where the UTC check occurred after 22:00 UTC.\nMode: Regular Chat, GPT-6 family, using primary-source web browsing. The actual reasoning-tier setting is not independently exposed by the research tools; no Pro-tier or comparative capability claim is made.\n\nScope: National authorisation and provider-capacity questions, with expressly bounded adjacent financial, professional, collection and statutory-relief regimes. This is neither an assessment of any actual provider nor a determination that a proposed business model is lawful.\n\n## 1. Principal findings\n\n### 1.1 South Africa has distinct legal categories that must not be combined\n\nThe operative National Credit Act (NCA) establishes a formal debt-review process, with registration of individual debt counsellors. The 2014 amendment separately establishes registration for payment distribution agents. The Debt Collectors Act regulates specified creditor-side collection activities. The Legal Practice Act regulates professional legal practice and specified reserved legal activities.\n\nThese are different legal capacities:\n\n| Activity | Initial authorisation conclusion | Claims |\n| --- | --- | --- |\n| General, non-individualised budgeting education | Does not by itself establish that statutory debt counselling is being performed; any applicable adjacent law must still be tested | C001, C005 |\n| Individual statutory debt review under NCA s86 | Requires an appropriately registered natural-person debt counsellor | C001–C004 |\n| Negotiating a voluntary creditor compromise outside statutory debt review | Not conclusively classified merely by the words “negotiation” or “settlement”; the actual acts, representations, debts and mandate control | C005, C006 |\n| Handling debt-review payments as a payment distribution agent | Separate NCR registration and statutory conditions apply | C007–C009 |\n| Collecting another person's debt for reward on the creditor's behalf | Potential Debt Collectors Act registration, subject to its definitions and exclusions | C010–C012 |\n| Charging for reserved litigation/document-preparation activities | Legal Practice Act restrictions apply when their precise predicates are met | C013 |\n| Sequestration, administration orders or business rescue | Distinct statutory processes with different actors and appointing authorities | C020–C022 |\n\nThe most consequential distinction is this: an NCR debt-counsellor credential does not authorise an entire company or its unregistered staff to conduct the statutory counselling function. Section 44(1) specifies a natural-person applicant, section 44(2) restricts the offering and performance of the regulated service, and section 163(1C), introduced in 2014, limits the debt counsellor’s use of agents to administrative tasks concerning debt review. [C001–C004; S001–S003]. justice.gov.za+2\n\nA second critical boundary is that debt counsellors must not themselves collect and distribute consumers’ debt-review payments under the substituted regulation 11. Payment distribution agents have their own NCR registration, requirements and safeguards. [C007–C009; S002–S004]. gov.za+2\n\n### 1.2 Debt-review coverage cannot be presumed for every debt\n\nThe National Credit Act applies principally through its definitions of credit agreements, consumers, credit providers and its territorial and contractual scope rules. Material branches include:\n\n- Whether the arrangement is a credit facility, credit transaction or credit guarantee under section 8.\n- Whether the parties dealt at arm’s length and the agreement was made within or has an effect within South Africa.\n- Whether a juristic-person exclusion applies under section 4(1).\n- Whether an agreement falls under the NCA's limited application provisions for incidental credit or juristic-person consumers.\n- Whether the person's obligation is a guarantee whose underlying credit agreement is itself covered.\n- Whether the particular agreement had already reached the section 130 enforcement stage when debt review was sought.\n\nA mortgagor and a guarantor can meet the NCA definition of consumer in relevant circumstances; neither a secured obligation nor an individual's signature alone settles all other conditions. A company's loan, sole proprietor's loan, personal guarantee and joint obligation must be separately classified. [C014–C018; S001–S002]. justice.gov.za+3\n\nThe 2014 amendment changed the debt-review enforcement exclusion in section 86(2) from a reference to section 129 to section 130. Any article still quoting the original 2006 formulation without the amendment is unsuitable for current publication. [C019; S001–S002]. gov.za\n\n### 1.3 Publication holds already established\n\n1. Do not advertise ordinary private negotiation as NCR-approved debt review merely because someone in the organisation holds a counselling credential.\n2. Do not describe creditor-side debt collection registration as permission to represent indebted consumers.\n3. Do not promise a guaranteed reduction, cancellation, protective stay, credit-record outcome or creditor agreement. The NCR has specifically warned against advance promises of percentage debt reductions. ncr.org.za\n4. Do not market the enacted 2019 debt-intervention scheme as operational without an affirmative commencement check. An enacted amendment and an effective remedy are not interchangeable.\n5. Do not assume an overseas registration is recognised in South Africa.\n\nThese are research and publication controls, not determinations about a particular business.\n\n## A–E. Detailed findings and decision rules\n\n### 1. Identify the service before identifying the licence\n\nThe decisive distinction is between an ordinary negotiated agreement with creditors and the statutory debt-review process under the National Credit Act (NCA).\n\n| Activity or claim | Governing test and preliminary conclusion | Evidence |\n| --- | --- | --- |\n| Teaching budgeting or publishing general information | The NCA's debt-counselling regulations define debt counselling by reference to the functions in NCA §86. General educational content alone is not established to be a §86 service. This is an activity-based distinction, not a general exemption from all laws. | C003, C005; S001 §86; S014 reg. 1 |\n| Paid individual advice and negotiating a voluntary compromise | No standalone, universally applicable “debt-settlement company” licence was established by the authorities reviewed. But that does not establish that every paid arrangement is unregulated: examine representations, actual §86 functions, reserved legal work, financial products, and payments separately. | C005–C006, C013, C028–C029 |\n| Taking a consumer through statutory debt review | A person providing the NCA debt-counsellor service must be individually registered with the NCR. An incorporated employer, agency or trade name does not inherit that person's status. | C001–C004, C024; S001 §§44, 47; S003 |\n| Receiving a debt-review payment and distributing it to creditors | Separate NCR payment-distribution-agent (PDA) registration applies to that service. A debt counsellor is prohibited by regulation from collecting and distributing consumers' money. | C007–C009, C026; S002 §12 inserting §44A; S004 regs. 10A, 11 |\n| Collecting a creditor's debt for reward | The Debt Collectors Act has its own definition, Council registration and exceptions. It is not a licence to represent the debtor in statutory debt review. | C010–C012, C037, C050; S007 §§1, 8, 25–26 |\n| Appearing or preparing documents where legal practice is reserved | The Legal Practice Act restricts defined paid court appearances, preparation of documents for court proceedings, use of professional titles, and acts reserved by other laws. It does not, on the text examined, reserve every form of non-litigation negotiation. | C013, C035; S009 §§24, 30, 33–34 |\n| Advising on or intermediating regulated financial products | FAIS is an activity-and-product test. It cannot be assumed to apply to every conversation about an unpaid loan; nor can a debt service that actually distributes or recommends covered financial products assume it falls outside FAIS. | C028, C047; S015, S025 |\n| Acting as an appointed administrator, trustee or business-rescue practitioner | Those are separate statutory capacities. A general negotiation mandate, company registration or debt-counselling credential does not create a court appointment, Master's appointment or CIPC practitioner licence. | C020–C022, C041–C042 |\n\nThese distinctions follow the actual enacted service definitions and allocation of authority, rather than an inference from a firm's name or its method of charging. justice.gov.za+7\n\n### 2. Debt and debtor classification comes first\n\nThe NCA does not encompass all obligations owed by everyone in South Africa.\n\n- Territory and contract: Section 4(1) addresses arm's-length credit agreements made in, or having an effect in, South Africa, subject to its exclusions. Section 4(3) makes clear that an otherwise covered credit agreement is not removed merely because its credit provider is located abroad. This establishes a nexus for credit agreements; the precise extension of every provider-duty provision to a foreign remote debtor adviser needs a further, fact-specific analysis. C014, C031.\n- Natural persons and juristic persons: The statutory definition of juristic person includes certain partnerships, associations and trusts. Section 4(1) excludes a juristic consumer meeting the ministerially determined asset/turnover threshold and certain large juristic-person agreements. Even where an agreement with a juristic consumer remains within some NCA provisions, §6 excludes Chapter 4, Part D—the over-indebtedness and debt-review provisions. Merely signing an agreement in a person's own name does not resolve whether the relevant consumer is a natural person or juristic person; the contracting parties and instruments control. C014–C015, C043.\n- Thresholds: Official Notice 713 of 2006 sets R1,000,000 for the §4 juristic-person asset/turnover threshold and R250,000 as the higher agreement-size threshold. These are verified figures in the 2006 notice, but a complete subsequent-notice supersession review through October 2026 was not achieved. They are not approved here as a live eligibility calculator. C043.\n- Guarantees and joint debt: Section 4(2)(c) makes NCA treatment of a credit guarantee depend on whether the underlying facility or transaction is covered. Section 8(5) supplies the credit-guarantee definition. A co-principal debtor and a surety/guarantor are different classifications; the 2015 regulation's joint consumers definition expressly excludes a surety or credit guarantor. Neither marriage, signature nor a shared address alone determines the branch. C016, C044.\n- Secured obligations: Section 8 expressly recognises mortgage agreements and secured loans as credit transactions; §9(4) categorises a mortgage as a large agreement. A mortgage is therefore not automatically outside the NCA merely because it is secured. The separate procedural and enforcement consequences are deferred. C017.\n- Different kinds of accounts: A lease of immovable property, specified insurance-related transactions and a qualifying stokvel transaction are excluded from the §8 credit-agreement definition. An incidental credit agreement has a specially limited application under §5—importantly including Chapter 4, Part D in part—so describing all store, service, medical or utility arrears as either wholly “inside” or wholly “outside” debt review would be incorrect. C018.\n\nPrimary text: NCA §§1, 4–9 and the 2006 threshold notice. justice.gov.za+5\n\n### 3. The statutory route is different from a private workout\n\nIn the statutory route, the consumer applies to a registered debt counsellor under §86. The counsellor assesses the prescribed circumstances, notifies specified parties, and may recommend a voluntary arrangement where the consumer is not over-indebted but is struggling. Where the statutory assessment supports an over-indebtedness proposal, the matter may proceed through the prescribed consent-order or Magistrates' Court route. Section 87 gives the court a decision-making role: the counsellor does not simply issue a binding unilateral debt-reduction order. C006, C038.\n\nSection 86(5) requires good-faith participation in the statutory review and negotiations described there. It must not be converted into a promise that a creditor must accept any proposed concession in an unrelated private workout. The 2014 amendment also changes the relevant enforcement-stage reference in §86(2); quoting the unamended 2005 provision as current would be unsafe. C019, C046. justice.gov.za+2\n\nA private workout is instead tested by the particular debtor–creditor–representative arrangement and any independently triggered law. An agreement to discuss a compromise is not itself an NCA §87 order, administration order, sequestration, company business rescue, or debt cancellation.\n\n### 4. Actor and claimed-exception matrix\n\n| Actor or structure | What must be established | Adverse branch |\n| --- | --- | --- |\n| Commercial debtor-paid negotiation firm | Actual advice, debt-review representations, mandate, fee recipient and payment flow. No money-handling conclusion from the words “debt settlement.” | If it undertakes §86 services without the requisite individual registration, the NCA §44 restriction is engaged; other reserved activities can trigger their own laws. C002, C005, C013, C029 |\n| Registered individual debt counsellor | Individual NCR status, permitted conditions, relevant qualifications, ongoing eligibility and the actual person responsible for §86 work. | A credential does not authorise incompatible debt collection or personal collection-and-distribution of client repayments. C001, C009, C024 |\n| Debt-counselling company, employee or “representative” | Identity of each registered natural person; employer's actual role; which tasks employees perform; limited NCA §163 administrative agency. | An employee credential cannot turn the company into an individually registered debt counsellor; a general agency contract does not confer full §86 powers. C004, C024 |\n| Free adviser, charity, nonprofit or consumer organisation | Whether genuinely only educating/referring, or actually performing regulated work; whether money or indirect benefit changes hands. | No blanket exemption from §44, legal-practice restrictions or payment rules was verified for “free” or “nonprofit” status. C005, C036 |\n| Attorney, advocate or legal clinic | Admission, current practising enrolment, permitted practice form, actual mandate and any legal-clinic approval or supervision. | Professional status cannot substitute for separate NCA PDA registration or automatically grant every statutory debt-counselling capacity. C013, C035 |\n| Accountant or other adviser | Actual professional qualification and work; whether court-reserved acts, §86 work, FAIS products or payment functions are added. | “Accountant” is not a blanket statutory debt-review exemption. C013, C028, C036 |\n| Original creditor collecting its own claim | Ownership of the claim, identity of payee and agents, and underlying NCA credit-provider duties where applicable. | It is not automatically a third-party Debt Collectors Act collector; that does not eliminate credit or collection-law obligations. C010, C037 |\n| Debt purchaser, collection agency, servicer or creditor-side attorney | Assignment/factoring terms, for-reward collection, the actual principal, registered personnel and specific statutory attorney or factoring exceptions. | Buying overdue debt can itself fall within the statutory collector definition; Council registration does not authorise debtor-side debt review. C010–C012, C037 |\n| Referral or software-only platform | Whether referrals, neutral records or calculations are the whole service, or whether the platform actually advises, holds itself out as a statutory provider or controls money. | A software interface does not remove the legal character of the underlying human or automated service. C005, C055 |\n| Payment service/PDA | NCR PDA category and, where actual movement or processing triggers it, SARB national-payment-system law. Exact payer, payee, bank account, authority to instruct and receipt of funds matter. | Neither an NCR debt-counsellor registration nor a generic “trust account” claim proves payment permission. C007–C009, C026, C029–C030 |\n| Public agency adviser | Statutory departmental function, employment or appointment and service actually offered; no inferred transferable private authority. | A public information service cannot be assumed to license an unrelated commercial actor. C036 |\n| Court administrator, insolvency trustee, liquidator or business-rescue practitioner | Specific statutory office, court or Master's appointment, or CIPC professional licence and appointment where applicable. | Marketing oneself as an “administrator” does not establish a court order or legally appointed office. C020–C022, C041–C042 |\n\nThe absence of a verified categorical nonprofit or professional exemption is a research limit, not proof that no narrowly defined exemption exists in any connected law. The exact applicable provision must be identified before reliance. justice.gov.za+6\n\n### 5. Which authority controls which capacity?\n\n| Body | Established role for this gateway | Limits on what its register proves |\n| --- | --- | --- |\n| National Credit Regulator (NCR) | Individual debt counsellors and separately registered PDAs under NCA §§44, 44A; registration conditions and public registrant information under Chapter 3. | Registration is category- and person-specific; no approval of a particular contract, settlement claim or fee is inferred. C001, C007, C023, C039 |\n| Council for Debt Collectors | Creditor-side collection registration under Debt Collectors Act §§8–12. | Not an NCR debt-review credential or permission to represent consumers. C010–C012 |\n| Legal Practice Council and courts | Practitioner enrolment/roll; admission and defined reserved legal functions; courts exercise their actual adjudicative powers. | Professional enrolment and a court order are different evidence. C013, C035 |\n| Financial Sector Conduct Authority (FSCA) | Licensing and oversight where FAIS-defined financial advice or intermediary services are actually supplied. | An FSP entry does not establish approval to provide every form of debt negotiation. C028, C047 |\n| South African Reserve Bank (SARB) | National payment-system law, directives and—in the September 2026 transition—the licensing/authorising/registration functions for NPS payment institutions previously handled through PASA's management structure. | Does not displace the NCR's distinct PDA category. C029–C030 |\n| Magistrates' Court | Debt-rearrangement adjudication under NCA §87 and administration-order appointments under Magistrates' Courts Act §74E. | Neither is created by a private representation agreement. C020, C038, C041 |\n| High Court and Master of the High Court | Insolvency sequestration proceedings and trustee appointment/security under Insolvency Act §§3, 6, 56–57. | An adviser or debt collector is not automatically a trustee. C021 |\n| Companies and Intellectual Property Commission (CIPC), company and court as applicable | Company registration is separate from licensed business-rescue-practitioner status; statutory business-rescue appointments follow their own process. | A CIPC incorporation record is not a business-rescue licence. C022, C042, C057 |\n\nThe SARB's own 2026 transition notice expressly dates the transfer of payment-institution authorisation functions to August/September 2026. This is a material currentness change, not an inference from its older website navigation. resbank.co.za+5\n\n### 6. Special financial and competence conditions actually read\n\nFor debt counsellors, NCA §46 creates individual disqualifications, including specified incapacity, insolvency and conflict-of-interest circumstances. An individual engaged in, employed by or acting for a business conducting debt collection, credit-bureau operations or credit provision encounters a specific debt-counsellor disqualification. The NCR's registration guide additionally describes Grade 12/NQF 4, an approved course and work-experience criteria. The guide's exact age, course, document and financial-history details are guidance, while the governing regulation 10 full current text remains a verification task. C024, C048. justice.gov.za+1\n\nFor PDAs, the 2015 gazetted regulation 10A supplies substantially more demanding conditions:\n\n- Qualifying incorporated entity structure, competent personnel, a suitable executive director and governance requirements—including three non-executive directors with the specified independence/experience condition.\n- Minimum capital of R5 million for establishing/operating the agency, evidenced at application in the stated bank-guaranteed-cheque form.\n- Insurance with the compensatory value linked to the aggregate money collected for distribution.\n- If debt counselling and payment distribution coexist, operationally independent businesses and separate managers, with no distribution for the operator's own debt-review clients.\n- An electronic distribution system and the regulation's required account/reporting arrangements.\n\nThese are requirements for the PDA registration category, not a universal R5 million requirement imposed on all private debt advisers. C026, C051. gov.za+1\n\n### 7. Currentness and enactment checkpoints\n\n2014 National Credit Amendment Act—PDA/debt-review changes\n\nCommenced 2015Read Act 19 of 2014 and the March 2015 implementing material; not every provision of the original 2005 PDF represents the amended rule. C007, C019.2019 National Credit Amendment Act—debt intervention\n\n2026 commencement unresolvedEnacted Act 7 of 2019 §32 expressly requires presidential proclamation. A dated government-department consolidation treats the provisions as pending; no controlling later proclamation was verified in this pass. Do not publish the new intervention route as operating merely because the Act was enacted. C032, C045.August 2025 draft NCA regulations\n\nWithdrawn draftA 12 November 2025 Department of Trade, Industry and Competition parliamentary briefing expressly says the August draft was withdrawn. Do not treat its proposed small-business reporting amendments as enacted law. C033.2026 payment oversight transition\n\nEffective September 2026SARB confirms PASA's management-body recognition withdrawal and the transfer of payment-institution licensing functions. The older SARB Act consolidation and Directive 1 of 2007 must be interpreted with that institutional change. C029–C030.Sources: enacted amendments, government commencement descriptions, 2025 departmental briefing and SARB 2026 notice. gov.za+4\n\n### 8. Two recomputed statutory-category cost examples\n\nThese examples use published 2016 government amounts, because that source supplies an explicit application fee and registration amounts. The NCR also still hosts an undated/older counsellor guide showing R100, inconsistent with the later gazetted R500 registration figure. The calculations are arithmetically verified against the 2016 instrument; they are not represented as live October 2026 quotations pending the amendment/supersession check. The amounts are regulator-facing, not consumer settlement charges. C025, C040, C049. gov.za+2\n\nEXAMPLE 1 · NATURAL-PERSON DEBT COUNSELLOR\n\n# R1,050\n\nPublished 2016 application + registration\n\nR550 application fee\n\n+ R500 registration amount\n\n= R1,050\n\nAssumes one qualifying new individual applicant; excludes branch charges, other actual expenses and later changes.EXAMPLE 2 · PAYMENT-DISTRIBUTION AGENCY\n\n# R100,550\n\nPublished 2016 application + registration\n\nR550 application fee\n\n+ R100,000 registration amount\n\n= R100,550\n\nSeparate from R5 million capital and insurance; assumes one qualifying initial registration.For a hypothetical PDA with R2,000,000 aggregate funds collected for distribution, the literal compensatory-value rule in regulation 10A(6) gives a corresponding R2,000,000 insurance reference amount: R2,000,000 × 1 = R2,000,000. The actual policy terms, measurement time, coverage evidence and regulator determination have not been examined; no insurance premium is calculated. The minimum capital remains R5,000,000, not R5 million plus an invented percentage of client debts. C026, C040, C051.\n\nIf a further qualifying premises or location falls within the 2016 notice's branch-fee provision, R250 per applicable location is a separate possible component. This does not establish how a remote firm or employee's office would be counted. No penalty, deadline or other amount is added to the examples. gov.za+1\n\n## E. Worked classification and capacity scenarios\n\nThese are hypothetical tests of the governing categories, not determinations that a particular business or borrower qualifies. Each adverse branch matters: changing the agreement, provider’s role, compensation, or flow of money can change the governing regime.\n\n### Scenario 1 — A debtor-paid firm offers “debt review”\n\nFacts assumed: A South African company charges consumers to assess unsecured credit debts, negotiates with lenders, and advertises that it can place clients “under debt review.” Its director has business experience but is not personally registered as a debt counsellor.\n\n1. Classify the promised activity. General education and a privately negotiated payment proposal are distinct from the statutory functions under NCA §86. The advertised ability to conduct debt review invokes the registered debt-counsellor regime; marketing language cannot supply the registration. [C003, C005–C006, C038]\n2. Identify the authorised natural person. NCA §44 requires the individual undertaking debt-counselling functions to hold NCR registration. A company incorporation document, registered trade name, or an experienced director is not equivalent. An employee cannot simply lend registration to the entire firm. [C001–C004, C054, C057]\n3. Separate money movement. If the firm also receives debtors’ repayment funds and distributes them to creditors, the activity must be classified independently against NCA §44A, regulation 10A and National Payment System requirements. A debt counsellor is expressly prohibited by NCA regulation 11 from collecting and distributing consumers’ funds. [C007–C009, C026, C029, C051]\n4. Adverse branch. If the company only offers a voluntary workout, do not label it a completed §86 debt review or promise statutory consequences. If it performs reserved debt-counselling functions without the appropriate registration, examine the exact contravention and applicable enforcement provision; do not infer that the client’s underlying credit debt disappears. [C005, C034, C038]\n\nDocuments to inspect: itemised services, engagement contract, debtor’s credit agreements, fee recipient, NCR registration certificate and status of each relevant individual, company/employment or agency relationship, creditor mandates, and a funds-flow diagram.\n\nDecision-makers: NCR for its registration categories; court or Tribunal only where the particular NCA procedure confers authority; payment regulator where the separate payment activity requires it.\n\n### Scenario 2 — “We are a charity, and our employee is qualified”\n\nFacts assumed: A nonprofit offers free budgeting consultations, accepts donations or lender referral payments, and assigns a registered debt counsellor to oversee a team of unregistered caseworkers.\n\n- Free education: No general NCA debt-counsellor licence requirement was established for the mere provision of general budgeting information. This is a bounded interpretation of the statutory activity definition—not a universal charity exemption. [C003, C005, C036]\n- Individualised statutory debt review: The registered individual must actually perform functions allocated to a debt counsellor. NCA §163(1C) permits administrative assistance subject to its terms; a worker performing substantive functions cannot be treated as authorised merely because a registered colleague supervises the office. [C001–C004, C054]\n- Funding: “Free to the debtor” does not settle whether someone is acting for reward under an activity-specific statute. Document donations, referrals, commissions and creditor payments before testing the Debt Collectors Act, FAIS or other potentially applicable rules. [C010, C028, C036, C055]\n\nDocuments: constitution and nonprofit status, all compensation/referral arrangements, individual NCR entries, supervision and task allocation, sample service descriptions, and any actual creditor authority. Adverse branch: qualification, charity status and free consultations cannot be combined into an invented blanket authorisation.\n\n### Scenario 3 — Debtor advocate, creditor collector, and debt purchaser\n\nFacts assumed: Three businesses call their service “settlements.”\n\n| Actual mandate | Initial statutory test | Important adverse branch |\n| --- | --- | --- |\n| A. Debtor pays A to seek a reduced balance from a lender | Test whether A performs NCA debt-counselling functions or other separately regulated professional/payment acts. | A is not automatically a debt collector merely because it negotiates a debt; the Debt Collectors Act definition focuses on recovering qualifying debts owed to another for reward. [C003, C005, C010] |\n| B. Creditor pays B to recover its outstanding accounts | Test Debt Collectors Act §§1, 8–10 for the actual person/entity and its applicable exception. | A collector registration does not confer NCR debt-counsellor status or the authority to represent the debtor. [C010–C012] |\n| C. C purchases overdue claims and pursues payment | The amended collector definition expressly addresses qualifying overdue purchased debts and distinguishes certain factoring. | Do not conclude “owning the debt” always exempts the purchaser; inspect assignment date, debt status, purchase purpose and statutory exception. [C010, C037] |\n\nDocuments: creditor or debtor mandate, chain of assignment, purchase agreement classification, remuneration, attorney status if invoked, relevant collector entries and individual/entity roles. Decision-maker: Council for Debt Collectors for that registration; NCR only for activity falling within its own mandate. A creditor’s choice to settle remains a separate contractual question.\n\n### Scenario 4 — A foreign call-centre advises South African debtors remotely\n\nFacts assumed: An overseas corporation has no South African office. It uses an English-language website and outbound calls to sell debt-specific negotiation services to residents. Some agreements were made with foreign lenders.\n\n1. Locate the debtor, credit provider, agreement-making, credit provision, service performance and payment-flow facts. NCA §4’s credit-agreement scope and its territorial extensions do not, by themselves, resolve every foreign adviser’s professional or business-regulation nexus. [C014, C031]\n2. Determine whether actual calls constitute statutory debt counselling, private negotiation, creditor collection, a regulated financial service, or transmission of funds. Each may have a different South African nexus test. [C003, C010, C028–C030]\n3. Ask the relevant statutory regulator about the category in the legislation using published guidance and registers; do not assume a foreign professional licence is recognised or that lack of a local office creates an exemption.\n\nDocuments: foreign incorporation and location facts, targeted South African advertising, contract governing law and performance clauses, underlying credit instruments, bank and beneficiary locations, employment/agency roles, and any claimed local permission.\n\nDisposition: Unresolved without a targeted cross-border statutory analysis. Do not represent either mandatory registration or exemption as established. Foreign assets, currency, judgments, governing law, recognition and migration are deferred to A098. [C031]\n\n### Scenario 5 — A natural person signs for a business loan or guarantees company debt\n\nFacts assumed: An individual signs a R600,000 agreement connected with a family company. The paperwork might identify the individual as the principal borrower, a joint borrower, a surety, or a guarantor; one version secures the debt over a home.\n\n- Do not classify from the person’s name or loan purpose alone. Examine the borrower named in the enforceable agreement, whether it is an arm’s-length NCA credit agreement, the parties’ juristic-person status, the relevant agreement type, and any guarantee’s relationship to the underlying agreement. [C014–C018, C044]\n- Separate the homeowner’s security from borrower status. A mortgage agreement can fall within statutory credit categories, but the security instrument does not alone establish every participant’s eligibility for debt review. [C016–C017]\n- Recheck thresholds against an operative notice. The primary 2006 threshold notice states R1 million for a specified juristic-person exclusion and R250,000 for the large-agreement classification. The research did not complete a 2026 supersession chain. Never treat R600,000 as establishing coverage by itself. [C015, C043]\n- Adverse branch: a company borrower or a natural-person surety may produce different statutory outcomes from an individual who is the principal consumer. Joint signature does not merge separate legal capacities. [C015–C016, C044]\n\nDocuments: original and varied loan agreements, company registration and membership/shareholding facts relevant to statutory definitions, guarantee/suretyship, all mortgage/security instruments, original principal amount and classification date, credit-provider identity, and any debt-review documents. Decision-maker: competent NCR-registered counsellor for an actual §86 application and ultimately the statutorily empowered court/Tribunal for relevant orders; not a generic private settlement firm.\n\n### Scenario 6 — Private advice versus an appointed statutory office\n\nFacts assumed: A consultant offers to “take over all creditor payments” and claims to be able to place (a) an individual under a magistrate’s administration order, (b) an insolvent estate into sequestration, or (c) a company into business rescue.\n\n| Mechanism invoked | Capacity test | What a consultant cannot establish by contract alone |\n| --- | --- | --- |\n| Magistrates’ court administration | The court’s statutory order and appointment of an administrator under Magistrates’ Courts Act §§74 and 74E; applicable qualification/security obligations. [C020, C041] | That a privately engaged payment manager already holds the court-appointed administrator’s powers. |\n| Sequestration or insolvent estate administration | Insolvency Act court order and the Master’s statutory appointment/security regime for a trustee. [C021] | That “insolvency consultant” or “trust-account holder” means appointed trustee. |\n| Company business rescue | Companies Act professional categories and licensing framework, plus appointment in the actual company proceeding. [C022, C042] | That a CIPC company registration or a consultant’s advertised rescue expertise is an actual practitioner appointment. |\n| NCA debt review | Registered individual counsellor and §86/§87 statutory process. [C001, C038] | That any private debt-negotiation contract is a court-sanctioned debt-rearrangement order. |\n\nDocuments: actual order, appointment certificate or notice, professional register result, capacity and identity of the office-holder, security/conditions if applicable, estate/company identity, and proposed funds custody.\n\nAdverse branch: these four routes are not interchangeable. This pass does not determine their complete eligibility, costs, forms, effect on security, or discharge rules.\n\n### Two quantitative permission-cost/safeguard checks — with limits\n\nThe dated primary material supports arithmetic for historic prescribed registration amounts and a payment-distribution safeguarding example. It does not establish today’s payable amount or any consumer settlement price.\n\nExample A — 2016 debt-counsellor registration notice\n\nAssumed one new application under the categories shown in Government Notice 514 of 2016.\n\n- Application component: R550\n- Listed debt-counsellor registration component: R500\n- Historical arithmetic: R550 + R500 = R1,050\n\nThis is not a 2026 quotation, consumer fee, or approval guarantee. The government notice’s subsequent amendment/supersession chain and current payment directions require separate verification. [C025, C040, C049]\n\nExample B — 2016 PDA category plus independently required protection\n\nAssumed one new payment-distribution-agent registration application under the same dated notice.\n\n- Application component: R550\n- Listed PDA registration component: R100,000\n- Historical arithmetic: R550 + R100,000 = R100,550\n- Illustrative aggregate consumer-funds exposure: R2,000,000\n- Illustrative indemnity needed to cover that aggregate exposure: R2,000,000, subject to the precise required coverage assessment\n- Separately specified regulation 10A financial-capacity criterion: R5,000,000, not a component of the R100,550 registration sum\n\nR2 million is a hypothetical exposure, not a standard premium, a legally sufficient policy in every case, a trust-account deposit or a cap. The R5 million requirement has its own stated regulatory form and predicates. This arithmetic proves neither current registration cost nor lawful handling of a particular consumer’s funds. [C025–C026, C040, C051]\n\n### D. Public, read-only verification sequence\n\n1. Write the activity statement first: who advises whom; whether any NCA §86 assessment/application occurs; who makes creditor offers; who represents each side; who receives remuneration; who receives, holds or directs funds.\n2. Classify the debt and parties: individual versus juristic consumer, principal versus surety/joint debtor, credit agreement and statutory exclusions, creditor and assignee, plus location and timing. Preserve uncertain branches. [C014–C018, C043–C044]\n3. Match each distinct permission to its statutory actor: NCR individual debt counsellor; NCR payment distribution agent; Council for Debt Collectors collector; FSCA financial-service category if genuinely triggered; relevant payment authorisation; LPC admitted professional; court/Master/CIPC route for an actual statutory appointment. [C001, C007, C011, C020–C030, C035, C041–C042, C047]\n4. Use official category and status materials, including [NCR public registers](https://ncr.org.za/register/index.html?utm_source=chatgpt.com), [Council for Debt Collectors register](https://www.cfdc.org.za/active-register/?utm_source=chatgpt.com), [Legal Practice Council practitioner search](https://lpc.org.za/members-of-the-public/search-practitioners/?utm_source=chatgpt.com) and [CIPC business-rescue practitioner information](https://www.cipc.co.za/?page_id=4745&utm_source=chatgpt.com). This research did not search a named provider or practitioner. A result would require checking the right individual, company, category, effective date, restrictions and any relevant appointment. [C039, C056–C057]\n5. Record a bounded answer: verified category and date; activity matched or not yet matched; unread agreement/mandate; unresolved funds flow and foreign nexus; next official source or responsible authority. Registration cannot prove creditor consent, compensation terms, contracts, all service permissions, or that a legal outcome will follow. [C039, C056]\n\nNo actual licences, persons, cases or providers were investigated; no application, contact, complaint, filing, payment or register submission was made.\n\n## Source register — C_ZA-P01-S001 onward\n\nReading convention: `PDF Pn` is a zero-based file page index; `GG p.n` is the page printed in the Government Gazette, where identified. Statute section numbers and regulatory paragraphs are the controlling pinpoint; a PDF’s file-page index is not a statutory section. “Opened” means the identified material was read during this pass, not that the entire instrument, every amendment or every later commencement notice was audited.\n\nActual access/check date: 26 October 2026, America/Los_Angeles (PDT), and 26–27 October 2026 UTC/South African Standard Time as the research crossed those date boundaries. “2026-accessed” never means “proven legally unchanged through 2026.”\n\n### National Credit Act and NCR materials\n\n| ID and issuing source — full direct URL | Actual pinpoint and page identification | Version, status, scope and reading limit |\n| --- | --- | --- |\n| S001 — Parliament, National Credit Act 34 of 2005, Justice-hosted enacted text. `https://www.justice.gov.za/mc/vnbp/act2005-034.pdf` | Definitions §1, application §§4–9, NCR §14, debt counsellors §§44–52, debt-review §§85–89. Relevant PDF P8–21, P23, P36–40, P59–62; Gazette printed-page correspondence not fully verified. | Opened 26 Oct 2026. Original enacted Act, not a complete current consolidated text. Applied with S002 and commencement qualifications; the original file alone cannot establish an unamended 2026 rule. Republic/covered credit/registered actors. justice.gov.za |\n| S002 — Parliament, National Credit Amendment Act 19 of 2014, Government Gazette 37665. `https://www.gov.za/sites/default/files/gcis_document/201409/37665gon389.pdf` | Insertion of §44A, amended §86 and insertion of §163(1C), with changes to §89. Relevant PDF P5–6, P11–12, P14–15; the corresponding printed Gazette numeration was not independently reconciled for each passage. | Opened 26 Oct 2026. Enacted amending text, with major provisions commencing in March 2015; this research did not establish a complete provision-by-provision commencement table. Read only cited amendments. gov.za |\n| S003 — National Credit Regulator (NCR), August 2022 debt-counselling media release. `https://www.ncr.org.za/documents/Media%20release%20-%20Debt%20counselling%20Campaign(August)-Final.pdf` | Advice on registered individual counsellors, debt review and payments: PDF P0–2; printed pagination not separately established. | Opened 26 Oct 2026. Official regulator explanation, not an enacted exemption or independent source of criminal liability. It does not establish a 2026 fee schedule. ncr.org.za |\n| S004 — Minister, National Credit Regulations amendment, Government Notice R202, GG 38557, 13 March 2015. `https://www.gov.za/sites/default/files/gcis_document/201503/38557rg10382gon202.pdf` | Regulation 10A(1)–(9): PDF P3–8, printed GG pp.8–13; amended regulation 11: PDF P11, printed GG p.16. Critical specific parts: 10A(3)(b)–(c), (5), (6), (7), (9)(f)–(g). | Opened and rechecked 26 Oct 2026. Final gazetted amendment governing NCR PDA registration and separation; further later amendments not exhaustively excluded. Reg10A(7) additionally requires no distribution for consumers of the applicant’s own debt-counselling business. Regulation 11 prohibits counsellors themselves from collecting/distributing consumer monies. gov.zagov.zagov.za |\n| S005 — NCR, Requirements for Registration as a Payment Distribution Agent. `https://ncr.org.za/documents/pages/PDA/Requirements%20for%20registration%20as%20a%20payment%20distribution%20agent.pdf` | PDF P0–1, issuer document page numbers not independently established; institutional and capability requirements cross-check S004 reg10A. | Opened 26 Oct 2026. Undated administrative guide; useful confirmation that PDA is an entity category, not a general natural-person debt-counsellor endorsement. S004 controls over a conflicting guide. ncr.org.za |\n| S006 — Minister, prescribed application, registration and renewal amounts, Government Notice 514, GG 39981, 11 May 2016. `https://www.gov.za/sites/default/files/gcis_document/201605/39981gon514.pdf` | Amended Schedule 2 item 2: PDF P1 / GG p.7 (R550 application); item 3 Tables C and D: PDF P3 / GG p.9 (R500 debt counsellor; R100,000 PDA); item 4: PDF P4 / GG p.10 (R250 branch). | Opened/rechecked 26 Oct 2026. Final 2016 rule; complete subsequent supersession/fee update chain not certified. These are registration charges, not borrower debt-counselling or settlement fees. gov.za |\n| S010 — NCR, Public Register navigation. `https://ncr.org.za/register/index.html` | HTML, registered/cancelled/lapsed debt-counsellor and PDA category paths; PDF index not applicable; opened page navigation rather than person/entity results. | Opened 26 Oct 2026. Official public lookup entry point; no named lookup performed and no particular registration established. ncr.org.za |\n| S011 — South African Government, National Credit Act legislative record. `https://www.gov.za/documents/national-credit-act` | HTML, Act title and enactment/commencement metadata; PDF index not applicable. | Opened 26 Oct 2026. Official discovery and legislative-context page, not a substitute for section text and amendment commencement. South African Government |\n| S012 — Parliament, National Credit Amendment Act 7 of 2019, GG 42649 alternative official Gazette copy. `https://www.gov.za/sites/default/files/gcis_document/201908/42649gon1081.pdf` | New debt-intervention provisions including §86A: PDF P14–16; §31 transition and §32 commencement: PDF P40 / GG p.42. | Opened/rechecked 26 Oct 2026. Enacted 2019 amending Act whose §32 requires presidential proclamation. No operative 2026 proclamation was established here. Therefore its proposed inserted debt-intervention pathway is not represented as in force. Government’s separate Act listing was also consulted. gov.zagov.za |\n| S013 — Department of Trade, Industry and Competition (dtic), Debt Review presentation. `https://www.thedtic.gov.za/wp-content/uploads/Debt-Review.pdf` | Statutory-role process discussion: PDF P6–8; slides have their own visible sequence, not Gazette pages. | Opened 26 Oct 2026. Official educational presentation distinguishing registered natural-person debt counsellor from juristic PDA; describes practice but does not independently enact qualifications, fees or court outcomes. thedtic.gov.za |\n| S014 — Minister, original National Credit Regulations, Government Notice R489, GG 28864 (2006). `https://www.gov.za/sites/default/files/gcis_document/201409/28864.pdf` | Regulation 1 definition of debt counselling, PDF P7 / GG approximately p.10; full operative regulation 10 text was not successfully re-opened in this pass. | Partially opened 26 Oct 2026. Original regulation; must be layered with 2015 amendments and later notices. Later attempts at the full source returned internal errors, so its qualification specifics remain partly unresolved. gov.za |\n| S023 — Minister, credit-agreement threshold notice, Notice 713, GG 28893 (2006). `https://www.gov.za/sites/default/files/gcis_document/201409/28893.pdf` | Notice paragraphs 2–3: PDF P0 / printed GG p.3; R1 million juristic-person threshold and R15,000/R250,000 agreement-class thresholds. | Opened 26 Oct 2026. Official 2006 figures, not demonstrated to be the last legally operative amounts in Oct 2026; the relevant NCA classification tests remain separate. gov.za |\n| S024 — NCR, Requirements for Registration as a Debt Counsellor. `https://ncr.org.za/documents/pages/compliance&reports_cp/Requirements%20for%20registration%20as%20a%20debt%20counsellor.pdf` | PDF P0–1; course, education, experience and an older “R100” amount. No dependable date in the document. | Opened 26 Oct 2026. Undated/outdated guide: its R100 is inconsistent with S006’s subsequent R500. It is not evidence that R100 is a current payable registration charge. ncr.org.za |\n| S029 — dtic, dated consolidation of National Credit Act. `https://www.thedtic.gov.za/wp-content/uploads/National_Credit_Act34of2005.pdf` | Consolidated §44/§86 framework and amendment markers: relevant PDF P35–40 and P75–79; internal printed-page alignment varies with layout. | Opened 26 Oct 2026. Dated compilation useful for tracing older amendments, not a 2026-certified consolidation. Its notes were not used as proof that no later proclamation exists. thedtic.gov.za |\n| S035 — NCR Annual Report 2024/25, published through dtic. `https://www.thedtic.gov.za/wp-content/uploads/NCR-Annual-Report-2024_2025.pdf` | Debt-counselling qualification discussion PDF P24; NCR compliance, PDA supervision and enforcement PDF P44–45, report printed pp.44–45 in Part B. | Opened 26 Oct 2026. Official regulator retrospective evidence: training expectations, compliance monitoring and that actual enforcement requires an adjudicative process. It reports two category-related Tribunal outcomes without this research opening either underlying decision. Historical programme description, not proof of all 2026 criteria. thedtic.gov.za |\n\n### Debt collection, legal practice and related professional authority\n\n| ID and issuing source — full direct URL | Actual pinpoint and page identification | Version, status, scope and reading limit |\n| --- | --- | --- |\n| S007 — Parliament, Debt Collectors Act 114 of 1998, Justice-hosted annotated text. `https://www.justice.gov.za/legislation/acts/1998-114.pdf` | §1 definitions and exclusions PDF P0; registration §§8–10 PDF P2; register §12 PDF P3; offences/exemptions §§25–26 PDF P6. Printed internal statute page numbers broadly 1–7, not official GG pagination. | Opened 26 Oct 2026. Justice-hosted amended statute; amendment dates to be verified separately for a definitive consolidation. Covers collection for another, specified purchasers and actual statutory exceptions; not automatic authorisation for debtor-side debt review. justice.gov.za |\n| S008 — Minister of Justice, 2026 amendments to Debt Collectors Regulations, Government Notice 7207, GG 54273, 6 March 2026. `https://www.justice.gov.za/legislation/notices/2026/20260306-gg54273rg11951gon7207-DebtCollectors-Regulations.pdf` | Regulation 11 substituted tariff: PDF P0–1 / printed GG pp.52–53. Distinct item caps include the stated R1,225 and R610 qualifications. | Opened 26 Oct 2026. Final 2026 Gazette notice. Creditor-side collection-cost tariff, not a debtor-paid negotiation fee schedule. Its application predicates and per-item distinctions must accompany any consumer-facing treatment. justice.gov.za |\n| S009 — Parliament, Legal Practice Act 28 of 2014, Justice-hosted amended text. `https://www.justice.gov.za/legislation/acts/2014-028.pdf` | Admission and enrolment §§24 and 30, restrictions and practices §§33–34: PDF P11–15; internal compilation page numbering used, rather than Gazette p. | Opened 26 Oct 2026. Enacted/annotated text with provision-level commencement caveats. Does not establish that all ordinary debt explanations or all voluntary negotiations are reserved legal practice. Nor does attorney status confer NCR registration. justice.gov.za |\n| S025 — Financial Sector Conduct Authority (FSCA), New Financial Service Provider guidance. `https://www.fsca.co.za/New-Financial-Service-Provider/` | HTML provider and representative regulatory route; PDF index not applicable. | Opened 26 Oct 2026. Regulator operational guidance; only relevant when actual service is a defined financial service involving an applicable product. Does not establish that ordinary debt settlement always needs an FSP licence. fsca.co.za |\n| S026 — Council for Debt Collectors, active register entrance. `https://www.cfdc.org.za/active-register/` | HTML public register interface; PDF index not applicable. | Opened 26 Oct 2026. Official capacity-check route; no named collector was queried. A listing alone does not establish which particular engagement is authorised. Debt Collectors Register |\n| S027 — Legal Practice Council, Search Practitioners interface. `https://lpc.org.za/members-of-the-public/search-practitioners/` | HTML public search instructions; PDF index not applicable. | Opened 26 Oct 2026. Official professional-capacity route; no named practitioner lookup conducted. Admission and a particular client mandate remain distinct. Legal Practice Council |\n\n### Payment systems, court appointments, corporate rescue and currentness materials\n\n| ID and issuing source — full direct URL | Actual pinpoint and page identification | Version, status, scope and reading limit |\n| --- | --- | --- |\n| S015 — Parliament, Financial Advisory and Intermediary Services Act 37 of 2002, government-hosted original. `https://www.gov.za/sites/default/files/gcis_document/201409/a37-020.pdf` | §1 defined “financial product,” “advice” and “intermediary service”: PDF P3–4; §7 licensing identified, but its currently amended complete body and exemptions were not fully read. Printed enactment pagination not separately recorded. | Partially opened 26 Oct 2026. Original Act, not reliable alone as a 2026 consolidation. Consequently FAIS is a conditional activity/product screen, not a conclusion that debt negotiators all require FSCA registration. gov.za |\n| S016 — Parliament/South African Reserve Bank (SARB), National Payment System Act 78 of 1998, SARB-hosted amended compilation. `https://www.resbank.co.za/content/dam/sarb/what-we-do/payments-and-settlements/regulation-oversight/NPS%20Act.pdf` | §7, regular acceptance of money/payment instructions for payment to a third party: PDF P9–10; binding directions §12: PDF P14. Printed statute-page numbering not independently mapped. | Opened 26 Oct 2026. SARB-hosted text incorporating significant amendments through approximately 2008; not certified fully consolidated through 2026. The amended §7 takes priority over an obsolete original. Do not equate NCA PDA permission with every required payment-system permission. resbank.co.za |\n| S017 — SARB, Payment System Management Body transition page. `https://www.resbank.co.za/en/home/what-we-do/payments-and-settlements/psmb` | HTML sections describing 2026 functional transfer and 2 September 2026 high-value arrangement change; PDF index not applicable. | Opened 26 Oct 2026. Current regulator operational announcement; not an all-category licensing instrument. PASA’s earlier PSMB role cannot simply be carried forward unchanged. resbank.co.zaresbank.co.za |\n| S018 — Parliament, Magistrates’ Courts Act 32 of 1944, Justice-hosted amended text. `https://www.justice.gov.za/legislation/acts/1944-032.pdf` | Administration order §74: PDF P32; appointment §74E: PDF P35; account/funds-related §74J: PDF P37; §74P: PDF P38. Printed amended-act page numbers not separately verified. | Opened 26 Oct 2026. National statute for a distinct court-controlled procedure. Not evidence of a private firm’s appointment or universal consumer access to an order. justice.gov.za |\n| S019 — Minister, Companies Regulations 2011, government-hosted Part C. `https://www.gov.za/sites/default/files/gcis_document/201409/34239rg9526gon351c.pdf` | Business-rescue practitioner licensing criteria, regulations 126–127, PDF P20–23; printed Gazette page number not independently reconciled. | Opened 26 Oct 2026. Final subordinate rules and qualification categories. The complete currently amended Companies Act §138 was not successfully opened; this source alone cannot decide a particular rescue appointment. Part C |\n| S020 — Parliament, Insolvency Act 24 of 1936, Justice-hosted amended text. `https://www.justice.gov.za/legislation/acts/1936-024.pdf` | Debtor’s petition and court acceptance §§3, 6, PDF P3–5; trustee appointment/security/removal §§56–57, 60, PDF P31–34. Printed compilation page mapping not verified. | Opened 26 Oct 2026. Distinct court/Master legal capacity; not a voluntary settlement licence. The full estate process, discharge and priorities were not reviewed. justice.gov.za |\n| S021 — dtic briefing to parliamentary portfolio committee, 12 November 2025. `https://www.thedtic.gov.za/wp-content/uploads/re-Revised-Part-A-Regs.pdf` | Label and description of withdrawn 2025 draft National Credit Regulations, especially PDF P1, P4–7, slide labels approximately 2 and 5–8. | Opened and rechecked 26 Oct 2026. Government explanation of withdrawal, not a statute. Crucial limit: relates to the August 2025 draft credit-information/SME amendments, not proof that every possible 2025 NCA rule or all future proposals were withdrawn. thedtic.gov.za |\n| S022 — SARB, Directive 1 of 2007 on payments to third persons. `https://www.resbank.co.za/content/dam/sarb/what-we-do/payments-and-settlements/regulation-oversight/D1_2007(ThirdParty).pdf` | Third-party payer/beneficiary-agent directions and associated requirements, PDF P1–3; original directive pagination distinct from PDF index and not independently matched. | Opened 26 Oct 2026. SARB-issued directive, not general debtor-payment permission. Its status alongside the 2026 transfer of PSMB functions and subsequent instruments needs an updated NPS rule-by-rule check. resbank.co.za |\n| S028 — Companies and Intellectual Property Commission (CIPC), business-rescue practitioner public information. `https://www.cipc.co.za/?page_id=4745` | HTML practitioner/licensing status listing with 7 October 2026 page update; PDF index not applicable. | Opened 26 Oct 2026. Public CIPC category/status information; no named practitioner was queried. A category listing is not itself an appointment to a particular company. CIPC |\n| S030 — CIPC, Business Rescue Practitioner information. `https://www.cipc.co.za/?page_id=4635` | HTML descriptions of licence and appointment route, including its reference to Companies Act §138; PDF index not applicable. | Opened 26 Oct 2026. Competent registrar’s guidance. The precise currently amended statutory text and each practitioner category’s full conditions still require operative-act verification. CIPC |\n| S033 — Minister, 2011 Companies Regulations forms appendix. `https://www.gov.za/sites/default/files/gcis_document/201409/34239rg9526gon351i.pdf` | Example CoR 126.1 application/licensing template, PDF P7–8; Gazette printed page not independently captured. | Opened 26 Oct 2026. An issued 2011 form only. It does not prove an individual licence, a current filing version or any appointment. No form submitted. Part I |\n\n### Discovery, obsolete comparisons and regulator-specific records\n\n| ID and issuing source — full direct URL | Actual pinpoint and page identification | Version, status, scope and reading limit |\n| --- | --- | --- |\n| S031 — Minister, August 2025 draft NCA regulations, GG 53154. `https://www.gov.za/sites/default/files/gcis_document/202508/53154rg11867gon6510.pdf` | Draft text PDF P0–3, but substantive scanned text not reliably extracted or verified; printed Gazette pagination not confirmed. | Discovery/partly unread only, accessed 26 Oct 2026. Subsequently withdrawn draft as described more precisely in S021 and S036; never used as operative permission or an enforceable requirement. gov.za |\n| S032 — Parliament, original National Payment System Act 78 of 1998. `https://www.gov.za/sites/default/files/gcis_document/201409/a78-98.pdf` | Original §7: PDF P4; printed enactment page not separately checked. | Opened 26 Oct 2026 as historical comparison; superseded wording. Do not cite its unamended §7 as the current payment-permission test; use S016 with further-currentness reservation. gov.za |\n| S034 — South African Government, FAIS Act legislative listing. `https://www.gov.za/st/documents/financial-advisory-and-intermediary-services-act` | HTML Act/amendment metadata; PDF index not applicable. | Opened 26 Oct 2026. Confirms the need to account for legislation later than S015; metadata only, not a complete operative FAIS exemption/license rule. South African Government |\n| S036 — dtic, Minister’s withdrawal statement, 12 September 2025. `https://www.thedtic.gov.za/minister-tau-withdraws-the-national-credit-act-amendment-regulations/` | HTML statement, paragraph beginning “The Minister … has withdrawn” and its description of the educational-institution credit-information issue; PDF index not applicable. | Opened 26 Oct 2026. Official explanation of a particular draft withdrawal, not an amendment or a general debt-counselling ruling. Read together with S021 rather than extending its subject matter. thedtic.gov.za |\n| S037 — NCR, Guideline 001/2026 concerning clearance certificates through CBA platform, February 2026. `https://www.ncr.org.za/documents/Guidelines/Guideline%20February%202026.pdf` | Background and guidance purpose PDF P1; platform directions P2; transition P3. Printed guideline pages 1–3. | Opened 26 Oct 2026. Demonstrates that NCR procedures and issued guidance can change during 2026. Clearance-certificate filing requirements, timing and credit-reporting outcomes are deferred, not adopted into this authorisation gateway. ncr.org.za |\n\nSource-register precision correction: S029’s specific PDF page ranges in the preceding table were not independently preserved in the read record. They should be treated as unverified indices, while its identified §44/§86 subject matter and dated-consolidation limitation remain the usable evidence. No consequential claim rests solely on those page ranges.\n\nFailed/not-read record: The separate official 2019 Act attachment associated with GG 42653 failed to open reliably; S012 is the successful official GG 42649 alternative. Reopening the full original 2006 regulations after an initial partial read also returned internal errors, and a further official primary text for current regulation 10 was not obtained. The Justice-hosted complete Companies Act file failed; CIPC and Companies Regulations were read, but are not substitutes for a current verbatim §138. No private contracts, regulatory decision files, provincial enactments or unpublished conditions of registration were obtained. These are evidence gaps, not proof of absence.\n\n## Atomic claim register — A097/A098 handoff identifiers\n\nEach `C_ZA-P01-Cnnn` is scoped to the identified activity, actor, agreement and legal regime. These are research claims, not country-level acceptance findings. “Conditional inference” means the conclusion follows from the stated statutory distinction but is not itself a separately enacted exemption. Where the amending-law chain remains incomplete, the claim is correspondingly limited.\n\n### Core activity, agreement and authorisation claims\n\n| Claim | Exact bounded proposition, conditions, act and consequence | Primary evidence and limit |\n| --- | --- | --- |\n| C_ZA-P01-C001 | In South Africa, a person who provides or holds themselves out as authorised to provide NCA debt-counsellor services must be registered for that category; the NCR’s framework treats the debt counsellor as the registered natural person. Registering a company or employee in another category does not meet this requirement. | S001 §44(1)–(3); S002 amendments to §44; S003 PDF P0–2; S013 P6–7. Read currentness with amendments; precise individual status unsearched. |\n| C002 | NCA §44(2) prohibits an unregistered person from offering, undertaking or holding themselves out as authorised for that statutory service. Consequences require the specific contravention/enforcement provisions; no underlying-debt cancellation follows solely from this prohibition. | S001 §44(2); S002; S035 P44–45. No particular enforcement case decided here. |\n| C003 | The National Credit Regulations define “debt counselling” by reference to the services/functions in NCA §86. The statutory function, not a marketing adjective alone, determines the category. | S014 regulation 1, PDF P7; S001 §86. Full regulation 10 currentness remains partial. |\n| C004 | An individual debt counsellor may use assistance within the limits of NCA §163(1C) for administrative functions; this is not a blanket delegation of statutory counselling authority to unregistered workers. | S002 inserted §163(1C), PDF P14–15. Which specific worker tasks are purely administrative requires facts. |\n| C005 | Conditional inference: providing general budgeting education or facilitating a wholly private consensual workout is not automatically an application or determination under §86. But describing an activity as “voluntary” or “free” does not excuse actual §86 functions or other triggered regulatory conduct. | S014 regulation 1; S001 §§44, 86; S007 §1; S015 §1. No universal unregulated-debt-advice safe harbour established. |\n| C006 | For a covered consumer’s statutory debt review, the registered counsellor’s assessment/recommendations and any competent Tribunal/court determination have defined roles under §§86–87; a private negotiator’s proposal is not itself that statutory order. | S001 §§86(6)–(8), 87; S002 amended §86. Complete procedural effects are deferred. |\n| C007 | NCA §44A establishes a separately registered payment distribution agent category. A debt-counsellor credential alone is not PDA registration, and regulator guidance distinguishes a debtor paying directly from using an appropriate PDA. | S002 inserted §44A, PDF P5–6; S003 PDF P1–2. Other payment legislation may apply independently. |\n| C008 | Under regulation 10A(3)–(4), a PDA applicant must satisfy specified organisational form, management, resource, competence, integrity and related tests; the listed structures include an incorporated company, close corporation or cooperative, plus the regulation’s stated board/experience conditions. | S004 PDF P3–5; S005 P0–1. Apparent differences between entity forms and prescribed board terminology require regulator-specific resolution; no application assessed. |\n| C009 | National Credit Regulations regulation 11, as substituted in 2015, prohibits a debt counsellor from collecting and distributing consumers’ money. Acting through a properly distinct authorised PDA is a separate assessment, not an exception allowing the counsellor personally to do both. | S004 PDF P11 / GG p.16; reg10A(7), P6. Full safeguarding and payment-design requirements deferred. |\n| C010 | The Debt Collectors Act §1 addresses qualifying recovery on behalf of another for reward, including specified recovery of overdue debts acquired for that purpose, subject to the text’s factoring and other exclusions. A debtor’s paid negotiator is not automatically in this category merely because creditors are contacted. | S007 §1, PDF P0. The actual mandate, assignment and compensation determine classification. |\n| C011 | When someone meets the Debt Collectors Act’s operative collector definition and no statutory exception applies, §§8–10 require registration/capacity for the relevant collector and associated roles. A collector’s registration is not an NCR debt-counsellor licence. | S007 §§8–10, PDF P2; S001 §44. Entity and officer/employee facts must be checked. |\n| C012 | Undertaking activity prohibited by Debt Collectors Act §8 can engage the §25 offence provision upon the legally required elements and process. This does not automatically void a debt, guarantee, judgment or security instrument. | S007 §§8, 25, PDF P2 and P6. No criminal finding or particular case examined. |\n| C013 | Legal Practice Act §§24, 30, 33–34 separately govern admission/enrolment and specified reserved paid professional legal functions. A claimed attorney, advocate or corporate legal practice must meet the applicable provision and capacity rules; ordinary debt-related conversation is not proved categorically reserved merely by invoking the Act. | S009 §§24, 30, 33–34, PDF P11–15. Provision-level commencement and detailed activity classification remain open. |\n| C014 | NCA §4 generally tests whether an arm’s-length credit agreement is made within, or has effect within, the Republic, subject to express limitations and exceptions. Neither residence nor loan label alone settles its application. | S001 §4(1)–(3), PDF P16–19. Agreement facts, foreign elements and amendment status still matter. |\n| C015 | A juristic-person consumer receives materially different NCA treatment: §4 contains the threshold and large-agreement exclusions, while §6 disapplies specified NCA provisions to agreements with juristic consumers that remain otherwise covered. Therefore a company’s covered credit contract does not automatically admit its debts into individual §86 debt review. | S001 §§1, 4, 6, 9; S023 ¶¶2–3. Threshold amendment search incomplete; classify legal borrower first. |\n| C016 | A credit guarantee/suretyship must be tested by NCA §§4(2)(c) and 8(5) against the underlying credit facility/transaction; a natural-person signatory’s name or the business use of funds does not alone prove consumer status or access to debt review. | S001 §§4(2)(c), 8(5), PDF P17–21. Terms and identities of principal and guarantor indispensable. |\n| C017 | NCA §8 recognises secured/mortgage credit agreements, and §9 helps classify agreement size. Security type is not a universal inclusion or exclusion: the parties and operative §4 exceptions still have to be tested. | S001 §§4, 8(4), 9. Mortgage enforcement and property-law effects deferred. |\n| C018 | Incidental credit, specified agreements/transactions and the express statutory categories are subject to NCA §§5 and 8(2) distinctions. An amount someone owes is not necessarily a covered “credit agreement” or a §86 debt-review item. | S001 §§5, 8(2). Product/debt-type-by-type analysis deferred. |\n| C019 | A credit provider’s actual steps contemplated by NCA §130 can affect whether an agreement may be included in an §86 debt-review application under amended §86(2). A threat or collector call is not assumed to satisfy the statutory trigger. | S001 §§86(2), 130; S002 amendment to §86, PDF P11–12. Exact service, date and proceeding facts were not evaluated. |\n| C020 | Magistrates’ Courts Act §§74 and 74E provides a separate administration-order mechanism in which the court exercises the relevant order/appointment powers. A voluntary contract with a payments company does not create that appointment. | S018 §§74, 74E, PDF P32, P35. Full order eligibility, asset and debt effects deferred. |\n| C021 | Insolvency Act §§3, 6, 56–57 allocates distinct functions to the court and the Master/trustee appointment and security regime. A commercial negotiator is not a trustee merely because it uses insolvency terminology. | S020 cited sections, PDF P3–5, P31–33. No estate, appointment or full insolvency remedy analysed. |\n| C022 | Business-rescue practitioner activity involves a CIPC licensing/professional-category framework under Companies Regulations 126–127, separately from the appointment required in the actual company proceeding. General CIPC incorporation does not equal such a licence or appointment. | S019 regs126–127, PDF P20–23; S030 HTML discussion of Companies Act §138. Current verbatim §138 and all licence conditions not independently reopened. |\n| C023 | The NCR is the NCA registration/supervision authority for debt counsellors and PDAs, with national statutory registration and conditions; registration does not confer all other professional, collection or payment permissions. | S001 §§14, 44–52; S002 §44A; S035 P44–45. Province-specific qualification reserved under C052. |\n| C024 | NCA §§46–47 and applicable regulations impose disqualification, education, experience and competence screens on relevant registrants. Holding a course certificate alone does not mean the NCR has registered an individual or that registration remains active. | S001 §§46–47; S002 corresponding amendments; S024 P0; S035 P24. Current full regulation 10/conditions chain unresolved. |\n| C025 | Government Notice 514 in 2016 states R550 general registration application, R500 debt-counsellor category, R100,000 PDA category and a qualified R250 per branch. These amounts attach to the notice’s own category, item and period, not to a debtor’s settlement price. | S006 item 2, Tables C–D, item 4; PDF P1, P3–4 / GG pp.7, 9–10. Not certified current for 2026. |\n| C026 | PDA regulation 10A(5) specifies R5 million minimum capital, evidenced as stated by a bank-guaranteed cheque; 10A(6) requires sufficient compensatory insurance measured against aggregate funds; 10A(7) separately requires independence and bars distributing funds for consumers of its own debt-counselling business. | S004 PDF P5–6 / GG pp.10–11. No specific 2026 licence or insurance contract reviewed. |\n| C027 | The March 2026 Debt Collectors Regulations tariff sets specified recoverable collector-side charges and item-dependent maximums, including the Gazette’s qualified R1,225 and R610 figures. They are not a general permission to charge debtors those sums for settlement advocacy. | S008 substituted regulation 11, PDF P0–1 / GG pp.52–53. Exact charge item, number of acts and debt basis required before any calculation. |\n| C028 | FAIS is potentially triggered when the actual act is defined financial advice/intermediary service concerning a defined financial product, with any applicable statutory exception; generic negotiation of an ordinary overdue account does not itself establish each element. | S015 §1, PDF P3–4; S025 provider guidance; S034 amendment listing. Partial: full currently amended §7 and exclusions not read. |\n| C029 | Under the SARB-hosted amended NPS Act §7, regularly accepting funds/payment instructions from one person for payment to another requires classification against the subsection’s authorised alternatives and applicable §12 directives. NCA PDA status, a trust account, or a software interface alone does not settle NPS compliance. | S016 §§7, 12, PDF P9–10, P14; S022 Directive 1/2007, P1–3. NPS consolidation and 2026 directives need further checking. |\n| C030 | SARB’s announced 2026 PSMB transition, including the 2 September 2026 handover, affects which body performs payment-system management functions. That institutional change does not itself authorise every payment business or automatically extinguish continuing instrument-specific obligations. | S017 regulator transition page; S016 §12. Exact present third-party provider category and any 2026 directive need separate determination. |\n\n### Temporal, exceptional, institutional and verification claims\n\n| Claim | Exact bounded proposition, conditions, act and consequence | Primary evidence and limit |\n| --- | --- | --- |\n| C031 | NCA §4 has territorial rules relevant to a credit agreement involving a foreign creditor or South African effect; it does not alone settle the extraterritorial licensing status of a remotely operating debt adviser. Determine each service, targeted market, location, mandate and fund flow before asserting South African permission or exemption. | S001 §4(1)–(3); S015 §1; S016 §7. Partial nexus inference; foreign-assets/judgment questions reserved to A098. |\n| C032 | National Credit Amendment Act 7 of 2019 §32 provides for commencement by presidential proclamation; enactment/publication in August 2019 is not the commencement event. A qualifying commencement proclamation had not been established in this research as at access on 26 Oct 2026. | S012 §§31–32, PDF P40 / GG p.42; S011 legislative metadata. This is unknown operative status, not a claim that no proclamation exists. |\n| C033 | The specific August 2025 draft NCA regulations concerning credit-information reporting, including the contested education/SME issue, were withdrawn according to dtic’s September statement and November parliamentary briefing. They cannot supply a binding 2026 permission requirement. | S021 PDF P1, P4–7; S036 12 Sep 2025 statement. Scope limited to that draft; no general claim about other NCA rules. |\n| C034 | The consequences for an unlawful credit agreement under amended NCA §89, including amended judicial treatment, are a different question from a counsellor/negotiator’s registration breach. Nothing in the read rules makes provider misconduct automatically cancel the customer’s underlying debt, release security or erase a judgment. | S001 §89; S002 amendment to §89; S035 P44–45. Actual relief, standing, judicial findings and contractual effects not adjudicated. |\n| C035 | Legal practice requires the relevant LPC admission/enrolment and valid entity/practice capacity under LPA §§24, 30, 34, with distinct conditions for legal-practice structures and qualifying clinics. A person’s professional title does not itself establish the actual engagement’s mandate. | S009 §§24, 30, 34, PDF P11–15; S027 public entry point. No professional searched. |\n| C036 | Conditional negative finding: no categorical exemption from actual NCA §44 debt-counselling functions was established merely for a charity, consumer organisation, nonprofit, free service, accountant, attorney or other qualified person. The activity, statutory text and any specific exception must be tested independently. | S001 §44; S002 §163(1C); S007 §1; S009 §§33–34. Not a claim that no activity-specific exemption anywhere exists. |\n| C037 | A creditor recovering its own claim is not automatically the same Debt Collectors Act actor as a person collecting an amount owed to another for reward; however the amended §1 expressly brings certain overdue debt purchasers into scope. A servicer’s mandate and assignment terms can move the result. | S007 §1; S001 §1 “credit provider” definitions. Actual purchase, factoring and remuneration facts required. |\n| C038 | Statutory debt review proceeds through NCA §86 application/assessment and the paths to a competent Tribunal or court under §§86–87. A private creditor workout may exist without those statutory acts, but cannot claim their procedural status or outcome. | S001 §§86–87; S002 amended §86; S013 P6–8. Full eligibility, forms, effects and timelines deferred. |\n| C039 | NCR’s public materials distinguish registered, cancelled and lapsed category records. A bare historic registration number does not establish present status, scope, employment, mandate, company authorisation, fee legality or creditor assent. | S010 public register entry point; S001 §§44–52. No live individual/entity search performed. |\n| C040 | Under the 2016 notice only, R550 + R500 = R1,050 for the illustrated application/category components, and R550 + R100,000 = R100,550 for the illustrated PDA components. Under regulation 10A(6), a hypothetical R2,000,000 aggregate amount collected for distribution yields an equivalent R2,000,000 illustrative compensatory value; R5,000,000 capital remains separate. | S006 item 2, Tables C–D; S004 reg10A(5)–(6). Arithmetic correct for stated assumptions, not 2026 fees, actual insurance suitability, consumer cost or debt reduction. |\n| C041 | For magistrates’ administration, the court appoints the administrator under §74E, subject to statutory eligibility/security criteria. Custody and accounting are not established simply by accepting client funds; §74J has distinct administrator duties. | S018 §§74E, 74J, PDF P35, P37. Whether a particular officer qualifies requires order and role documents. |\n| C042 | For company business rescue, CIPC licensing/category and actual company/court appointment are separate predicates. The professional status of one consultant does not automatically vest authority in their entire company or every employee. | S019 regs126–127; S030; S028. Current verbatim Companies Act §138 and specific appointment not verified. |\n| C043 | The 2006 official threshold notice contains R1,000,000 for the specified juristic-person §4 threshold and R250,000 for the large-agreement classification, alongside R15,000 small/other categories. These figures are historically sourced, not conclusively verified as current on 26 Oct 2026. | S023 ¶¶2–3, PDF P0 / GG p.3; S001 §§4, 9. Must check later operative notices before publishing a current eligibility cutoff. |\n| C044 | Joint signatures, a director’s signature, personal suretyship, borrower identity and guarantee status are distinct classification facts under NCA definitions/§§4 and 8. None alone establishes whose credit agreement is subject to §86 review. | S001 §§1, 4, 8, 86. Contract-specific inference; no assumption that joint borrowing and suretyship are legally identical. |\n| C045 | The enacted 2019 debt-intervention amendments must not be advertised as an operating statutory benefit unless their proclamation, commencement and presently operative procedures are independently demonstrated. | S012 §32; S011 legislative metadata. Publication hold, not determination of permanent noncommencement. |\n| C046 | NCA §86(5) addresses good-faith participation within statutory debt review; it must not be transformed into a promise that an ordinary private negotiator can compel a creditor to reduce principal or accept a particular workout. | S001 §86(5); S002 §86 amendments. No actual creditor response or settlement agreement reviewed. |\n| C047 | An FSCA-authorised financial-services provider and any legally relevant representative have a permission framework only to the extent the actual FAIS product and activity engage it; FSP/representative status is not a universal substitute for NCR, collector or court appointment. | S015 §1, §7 (partial); S025 FSCA route; S034 amendment metadata. FAIS current full amended body and category detail unresolved. |\n| C048 | NCA §44(3), §47 and regulation 10 impose an education/competence inquiry for individual debt-counsellor registration. NCR’s 2024/25 report identifies an approved course and describes its then-current short course as 10 days; a possible new occupational qualification was still under development then. | S001 §§44(3), 47; S024 P0; S035 P24. Historical course description is not a certified October 2026 qualification rule. |\n| C049 | An older, undated NCR guide states R100, conflicting with the later official 2016 R500 category. Chronology and instrument type mean the guide cannot displace the gazetted notice; neither establishes the full 2026 amendment chain. | S024 P1 versus S006 Table C, PDF P3 / GG p.9. Explicit source conflict; live fee remains unverified. |\n| C050 | Debt Collectors Act §26 provides for a ministerial exemption mechanism with its statutory conditions; it does not create an automatic exemption simply because the actor is nonprofit, philanthropic, professionally qualified or charges the debtor nothing. | S007 §26, PDF P6. Any specific valid exemption instrument and its beneficiary were not investigated. |\n| C051 | PDA regulation 10A(5)–(9) has its own bank-guaranteed-cheque capital evidence, indemnity, independent-business and payment-account duties, including collection into a bank trust account and distribution/reporting requirements. These duties attach to the regulated PDA, not every business describing itself as a trustee. | S004 reg10A(5)–(9), PDF P5–8 / GG pp.10–13. Client-money compliance, regulatory conditions and payment permissions deferred. |\n| C052 | NCA §50 addresses effect of NCR registration across the Republic subject to applicable provincial legislation. This is not proof that the laws of all nine provinces, courts, municipalities or specialised sectors have been examined. | S001 §50. Each province has an unresolved geographic research row below. |\n| C053 | NPS Act §12 supplies statutory authority for applicable payment-system directives; an actor must first fall within the direction’s defined scope, and any adverse consequence requires its actual operative predicate. | S016 §12, PDF P14; S022 Directive 1/2007 P1–3. No blanket claim of a criminal offence for every unregistered “payment administrator”; current 2026 instruments remain to be checked. |\n| C054 | A registered individual’s use of an employee or assistant does not let that employee perform every statutory §86 function under the individual’s number. NCA §163(1C)’s administrative task allocation and the actual performed functions decide the boundary. | S002 §163(1C), PDF P14–15; S001 §44. Individual staffing agreements and task logs unexamined. |\n| C055 | Pure referrals, educational software and calculation tools are conditionally distinct from personalised statutory counselling, collecting on a creditor’s mandate and controlling consumer payments. If implementation or compensation changes the function, reclassify it. | S001 §§44, 86; S007 §1; S015 §1; S016 §7. Activity-based inference; no safe harbour for all lead generators/software suppliers established. |\n| C056 | Public NCR, collector, LPC and CIPC registers are read-only category/status checks, not evidence of a particular service contract, debt-owner authority, consumer consent, fund safeguarding, creditor settlement or legal outcome. | S010, S026–S028 official interfaces; S001 §44; S007 §8; S009 §30. No named searches; results must be time-stamped if later obtained. |\n| C057 | Ordinary CIPC entity incorporation does not automatically grant an individual’s NCR debt-counsellor registration, a juristic PDA registration, an FSCA permission or a business-rescue practitioner appointment. Each follows its own statutory actor/category. | S001 §44; S004 reg10A; S015 §1 and conditional §7; S019 regs126–127; S030. Company-specific documents absent; current FAIS and rescue amendment checks pending. |\n\nThe claim register deliberately does not contain an asserted “general South African debt-settlement licence,” blanket professional/charitable exemption, or universal penalty that invalidates a debtor’s existing obligations. The opened authorities support activity-specific categories and leave meaningful classification and currentness questions unresolved.\n\n## F. Granular coverage and gap register\n\nThe statuses refer only to this narrow provider-perimeter pass:\n\n- `answered`: the stated narrow legal question has a bounded source-supported answer, not an assurance that no later relevant law exists.\n- `partial`: substantial primary evidence read, but a consequential predicate, amendment, instrument or application remains unresolved.\n- `unresolved`: no reliable substantive answer can yet be reached.\n- `excluded_with_reason`: explicitly reserved for a separate focused investigation; any cited claim supports only the boundary, not the deferred subject.\n\nIn this register, `C001` is the exact abbreviated identifier C_ZA-P01-C001, and similarly for all `C002`–`C057`. Each row cites the substantive location (the activity/authority findings, worked scenario or atomic claims), and states the next necessary task.\n\n### A. Activity and agreement perimeter\n\n| Row | Material question and finding location | Status and exact claim IDs | Missing evidence / next focused action |\n| --- | --- | --- | --- |\n| A01 | General advice/budgeting versus statutory debt counselling. Core activity comparison; Scenarios 1–2. | `partial` — C001, C003, C005, C036 | Test the particular personalised assessment, recommendations, marketing and any other professional rules; do not create a categorical education exemption. |\n| A02 | NCR debt-counsellor registration and holding out. Core provider table; Scenario 1. | `answered` — C001, C002, C004 | For any later actual actor, verify individual status/date and real task allocation; no lookup authorised here. |\n| A03 | Voluntary creditor negotiation, remission, repayment arrangements. Core comparison; Scenario 3. | `partial` — C005, C006, C038, C046 | Resolve legal-practice, collection, mandate and funds-flow triggers; no unconditional settlement right found. |\n| A04 | Payment collection/distribution boundary. Actor/authority findings; Scenarios 1 and 6. | `partial` — C007–C009, C026, C029, C051 | Reopen fully updated NPS law, directives, individual PDA conditions and client-funds rules; those substantive protections remain deferred. |\n| A05 | Natural person, sole trader and juristic person/business borrower. Credit-classification findings; Scenario 5. | `partial` — C014, C015, C043 | Apply definitions to each actual agreement; establish 2026 threshold notice chain and sole-trader contracting capacity. |\n| A06 | Guarantor, surety, joint borrower and director signature. Scenario 5. | `partial` — C016, C044 | Read actual borrower/guarantee/security instruments; review precise current guarantee and joint-application rules. |\n| A07 | Secured/mortgage versus incidental/other debts. Credit classification; Scenario 5. | `partial` — C017, C018 | Product-by-product coverage and special remedies deferred; no all-debt debt-review claim. |\n| A08 | Creditor’s own account versus third-party collector/purchaser. Scenario 3. | `partial` — C010–C012, C037, C050 | Specific assignment, factoring, remuneration, creditor mandate and applicable exemption must be read. |\n| A09 | Attorney/professional and FAIS perimeter. Actor matrix; Scenario 2. | `partial` — C013, C028, C035, C047 | Read full currently amended FAIS §7/exemptions; classify reserved legal activity and effective LPA sections. |\n| A10 | 2026 amendment/commencement/transitional screen. Temporal findings and source register. | `partial` — C032, C033, C045 | Obtain official full proclamation/amendment chains for 2019 debt intervention, NCA regulations, thresholds, FAIS and NPS. |\n| A11 | Unauthorized-activity consequences. Registration findings; Scenario 1. | `partial` — C002, C012, C034, C053 | Pin each violation to current element, enforcement body and actual remedy. No automatic debt/security/judgment extinction. |\n| A12 | Commercial company/CIPC/trade name versus regulatory permissions. Actor/authority findings; Scenario 6. | `answered` — C001, C008, C022, C057 | In a later real examination match separately each permission to the correct individual/entity and effective date. |\n| A13 | Foreign remote offering/advertising/nexus. Scenario 4. | `unresolved` — C014, C029, C031 | Read targeted NCA cross-border, relevant professional, payments, establishment and advertising rules for actual country/service/funds facts. |\n| A14 | Formal debt review versus debt intervention. Statutory comparison. | `partial` — C032, C038, C045 | Obtain and read an operative presidential proclamation (if any) and all associated regulations; no current benefit represented. |\n\n### B. Actor, exemption, remuneration and capacity matrix\n\n| Row | Actor and finding location | Status and exact claim IDs | Missing evidence / next focused action |\n| --- | --- | --- | --- |\n| B01 | Commercial debtor-paid negotiator — Scenarios 1 and 3; activity matrix. | `partial` — C003, C005, C028 | Determine whether the firm crosses §86, legal-practice, regulated product or money-handling boundaries in the exact engagement. |\n| B02 | Personally registered NCR debt counsellor — Scenario 1. | `answered` — C001–C004, C024 | Individual status/conditions not actually checked; identify which substantive tasks are performed. |\n| B03 | Debt-counselling company, employees and representatives — Scenarios 1–2. | `partial` — C004, C054, C057 | Obtain actual task chart, employment/agency authority, named registration and relevant conditions if authorised in later work. |\n| B04 | Free/nonprofit/charity/consumer organisation — Scenario 2. | `partial` — C005, C036, C050 | Test true activity, donations, indirect benefit and any expressly issued exemption; no blanket nonprofit exception. |\n| B05 | Attorney and advocate — professional actor findings. | `partial` — C013, C035, C036 | Read applicable professional practice/admission rules and precise reserved service, mandate and practice structure. |\n| B06 | Accountant/other professional — Scenario 2. | `partial` — C005, C028, C036 | Identify profession-specific statute, actual legal/financial advice and remuneration before claiming an exemption or additional authorisation. |\n| B07 | Creditor recovering its own claim — Scenario 3. | `partial` — C010, C037 | Separate ownership and collection for another; check credit-provider/NCA duties in a later conduct pass. |\n| B08 | Debt collector or collection company/personnel — Scenario 3. | `partial` — C010–C012, C027, C050 | Apply registration/exceptions to each statutory role; current fee tariff is not debtor-side advocacy permission. |\n| B09 | Debt purchaser and servicer — Scenario 3. | `partial` — C010, C037 | Read assignment, overdue status, acquisition purpose, factoring exception and servicing mandate. |\n| B10 | Referrer, lead generator or software-only supplier — activity findings. | `partial` — C005, C055 | Examine workflow, who decides/communicates proposals, compensation and whether money or client mandates pass through the intermediary. |\n| B11 | PDA and staff — capacity findings. | `partial` — C007–C009, C026, C051 | Operational category substantially identified; actual employee qualifications, full conditions and funds protection not cleared. |\n| B12 | Public adviser/public authority — authority matrix. | `partial` — C023, C036, C038 | Read precise statutory public-office functions/agency mandate. Official status alone is no blanket exception for outside commercial functions. |\n| B13 | Court administrator — Scenario 6. | `partial` — C020, C041 | Actual court appointment/order, qualifications and security; full administration-order procedure deferred. |\n| B14 | Trustee, liquidator or estate officer — Scenario 6. | `partial` — C021 | Insolvency trustee body and Master read; separate company-liquidator appointment and operative statutory powers require a focused reading. |\n| B15 | Business-rescue practitioner — Scenario 6. | `partial` — C022, C042, C057 | Obtain current Companies Act §138 body, CIPC conditions and actual appointment route. |\n| B16 | Direct fee/indirect commission/benefit — Scenarios 2–3. | `partial` — C005, C010, C028, C036, C055 | Read compensation arrangements and match statute-specific “reward,” advice/intermediation and professional tests; consumer fee rules deferred. |\n| B17 | Qualification, fitness, resources and training — NCR/DC/PDA findings. | `partial` — C008, C024, C026, C048 | Current complete regulation 10 and individual conditions; verify dated 2024/25 qualification description against any later final rules. |\n| B18 | Nonprofit, professional, employment and ministerial exceptions — Scenario 2. | `partial` — C004, C036, C050, C054 | Locate actual exemption instrument or express applicable provision, with its beneficiary and scope; no global exception established. |\n\n### C. Authorising/supervising body, financial capacity, nexus and cost\n\n| Row | Authority or requirement; finding location | Status and exact claim IDs | Missing evidence / next focused action |\n| --- | --- | --- | --- |\n| COV-C01 | NCR registers/supervises NCA debt counsellors and PDAs — authority matrix. | `answered` — C001, C007, C023, C039 | Actual status/conditions to be verified only if a later authorised named check is requested. |\n| COV-C02 | National Consumer Tribunal/court statutory decision roles — Scenario 1, §86 pathway. | `partial` — C006, C038, C046 | Proceeding-specific jurisdiction, application, effect, standing and judicial orders deferred. |\n| COV-C03 | Council for Debt Collectors — Scenario 3. | `answered` — C010–C012, C056 | Actual role and registration not searched; current exceptions/conditions require case facts. |\n| COV-C04 | Legal Practice Council — professional route. | `partial` — C013, C035, C056 | Current admission/practice rules and any clinic-specific permission in actual transaction. |\n| COV-C05 | FSCA/FSP/representative route — authority matrix. | `partial` — C028, C047 | Read current full FAIS text, defined product schedule, FSP category, representative and exemptions. |\n| COV-C06 | SARB/NPS, PSMB transition and other participant requirements — payment authority. | `partial` — C029, C030, C053 | Full post-2026 operative NPS text/directives and classification of actual provider/payment operations. |\n| COV-C07 | Court/Master/CIPC appointments — Scenario 6. | `partial` — C020–C022, C041–C042 | Verify current Companies Act and each actual appointment instrument, not just a professional register. |\n| COV-C08 | CIPC incorporation versus specialist authorisation — company boundary. | `answered` — C022, C057 | Any actual company’s category, licence and practitioner identity require separate checks. |\n| COV-C09 | NCR individual and PDA entity/capacity differentiation — authority matrix. | `answered` — C001, C007–C008, C054 | Independent entity/individual status, representative tasks and registration conditions not checked. |\n| COV-C10 | PDA regulatory capital/insurance — quantitative Example B. | `partial` — C026, C040, C051 | Actual policy wording, aggregate exposure, legally sufficient cover, current conditions and financial-resource evidence. |\n| COV-C11 | Application/registration/branch/periodic charges — Examples A–B. | `partial` — C025, C040, C049 | Full current fee amendment chain and any current renewal/agency tariff; the 2016 example remains dated. |\n| COV-C12 | Foreign operation/recognition/establishment — Scenario 4. | `unresolved` — C031, C057 | Specific foreign-to-South-Africa statutory nexus, professional recognition, permanent establishment and advertised service tests. |\n| COV-C13 | National registration effect versus provinces/locality — geographic register below. | `partial` — C023, C052 | Separate operative provincial/local law research in all nine provinces; no invented provincial debt-counsellor licence. |\n\n### D. Read-only verification, documents and consequences\n\n| Row | Verification subject and finding location | Status and exact claim IDs | Missing evidence / next focused action |\n| --- | --- | --- | --- |\n| D01 | Official public registration/status categories — five-step verification workflow. | `answered` — C039, C056 | Actual named search deliberately not performed; future lookup must preserve query date, category and restrictions. |\n| D02 | Professional enrolment and statutory appointment — workflow; Scenario 6. | `partial` — C035, C041–C042, C056 | Current practising status, actual court/Master/CIPC appointment and any limits; no actual person checked. |\n| D03 | Minimum documentary classification packet — workflow and all scenarios. | `answered` — C014–C018, C031, C037, C044, C055–C057 | Collect only if separately authorised later: agreements, capacity, services, remuneration, mandate, registration, funds flow. |\n| D04 | Verification limits: permission ≠ contract/outcome — workflow. | `answered` — C034, C039, C056 | Creditor assent and actual contract terms remain unavailable; no outcome promises. |\n| D05 | Unauthorized acts and available legal consequences — Scenario 1. | `partial` — C002, C012, C034, C053 | Exact element, version, regulator process and remedies; consumer-specific redress deferred. |\n| D06 | Official general precedent/enforcement text — researcher limitations. | `unresolved` — C002, C012, C034 | NCR annual report’s outcomes are summaries, not read primary Tribunal decisions. Future narrow official-judgment reading must record posture, holding, pinpoints and amendments. No full citator/nonexistence claim. |\n| D07 | Private contracts, terms and consent — hypothetical documentation. | `unresolved` — C005, C037, C055–C056 | No real service contract, assignment, consent, insurance policy or lender arrangement obtained; must not infer provisions. |\n| D08 | Published template versus operative permission — S033 and workflow. | `answered` — C042, C056–C057 | A 2011 issuer form proves its own published text/version only; not a current application or appointment. |\n\n### E. Statutory-solution boundary and worked examples\n\n| Row | Narrow mechanism or output | Status and exact claim IDs | Missing evidence / next focused action |\n| --- | --- | --- | --- |\n| E01 | Private voluntary workout versus §86/§87 debt review. Scenario 1 and 3. | `answered` — C005–C006, C038, C046 | Actual eligibility, procedural protection and order effects deferred. |\n| E02 | Registered counsellor, NCR, Tribunal and court roles. Statutory pathway. | `partial` — C001, C006, C023, C038 | Detailed competence/appeals/procedure/status effects reserved. |\n| E03 | Administration order as separate statutory route. Scenario 6. | `partial` — C020, C041 | Full thresholds, eligible debts, forms, cost, security and post-order mechanics reserved. |\n| E04 | Sequestration/insolvency as separate route. Scenario 6. | `partial` — C021 | Full estate, priority, discharge, asset and tax rules reserved. |\n| E05 | Company business rescue as separate route. Scenario 6. | `partial` — C022, C042 | Currently amended §138 and full company rescue procedures reserved. |\n| E06 | Six capacity/classification scenarios with adverse branches. Scenarios 1–6. | `answered` — C001–C009, C010–C022, C028–C031, C037–C044, C054–C057 | Hypotheticals are conditional; no specific party/provider/borrower eligibility concluded. |\n| E07 | Two historical financial examples and one aggregate-insurance check. Examples A–B. | `answered` for dated arithmetic; `partial` for present-day applicability — C025–C026, C040, C049, C051 | Recheck 2026 fee and safeguard chain before anyone uses the figures in an application. |\n| E08 | Complete debt-review and insolvency effects. Only narrow distinctions covered. | `excluded_with_reason` — C006, C018, C020–C022, C038 | Separate full statutory-solution work; no broad-country A097 acceptance. |\n\n### F. Explicitly deferred subjects — no substantive acceptance\n\nThese rows prevent the provider gateway from being mistaken for a completed South African debt-relief encyclopedia. The cited claim IDs identify only the relevant boundary; they do not establish the deferred rules.\n\n| Row | Deferred parent topic | Status and boundary claim IDs | Exact next focused research question |\n| --- | --- | --- | --- |\n| F01 | Consumer fee earning and timing for debt counselling/private negotiation | `excluded_with_reason` — C025, C049 | Which currently operative Act/regulation/NCR condition or valid guideline governs when each fee may be earned, charged or retained, for which service and person? |\n| F02 | Consumer fee caps, refunds and cancellation | `excluded_with_reason` — C025, C027, C049 | Separate any operative debt-counselling fee guideline, contractual/private-service fees and collector-side tariff; read triggers, cancellation/refund conditions and amendment history. |\n| F03 | Consumer contracts, disclosures, advertising and conduct | `excluded_with_reason` — C002, C005, C056 | What currently applicable NCA, consumer-protection, professional and contract requirements govern the exact advertised service and its written terms? |\n| F04 | Client money, trust accounts and payment safeguarding | `excluded_with_reason` — C007–C009, C029, C051, C053 | Map each account owner, beneficiary, custody interval, authorised payment category, reconciliations, indemnity, interest and permitted fund transfer under updated laws. |\n| F05 | Private remedies and contract claims | `excluded_with_reason` — C012, C034, C056 | What actual cause of action and remedy, against which actor, follows from proven facts? Distinguish provider liability from debt enforceability. |\n| F06 | Regulatory redress, complaints and enforcement | `excluded_with_reason` — C002, C012, C023, C053 | Identify current complaint channels, standing, jurisdiction, sanction elements, limitation and actual judicial/Tribunal remedies from operative primary law. |\n| F07 | Full debt-product catalogue | `excluded_with_reason` — C014–C018 | Classify every material credit and noncredit product, exclusions, contingent liabilities and special regimes, with current thresholds. |\n| F08 | Collection, validation and debt disputes | `excluded_with_reason` — C010–C012, C027, C037 | Read creditor/collector notices, proof, contested amounts, mandates and remedies under the exact applicable South African statute—not a foreign validation model. |\n| F09 | Prescription, limitation and revival | `excluded_with_reason` — C012, C018, C034 | Read the operative Prescription Act and debt-specific exceptions, acknowledgments, judgments and transitional rules. |\n| F10 | Credit reporting, bureau disputes and clearance certificates | `excluded_with_reason` — C038, C045 | Read current NCA §§70–72, regulations and 2026 NCR guidance, including operative filing and dispute procedures; S037 is not a completed rules audit. |\n| F11 | Courts, service, default, judgments and enforcement | `excluded_with_reason` — C019–C021, C034 | Identify court/Tribunal competence, process commencement, proper service, orders, remedies and applicable procedural rules before stating effects. |\n| F12 | Enforcement exemptions, wages, bank accounts and assets | `excluded_with_reason` — C020–C021, C034 | Read operative enforcement/protected-property legislation and applicable local forum rules for the type of debt/order. |\n| F13 | Mortgage, other secured debts and repossession | `excluded_with_reason` — C016–C017, C021 | Analyse real-security instruments, foreclosure/repossession processes, ownership, priority and judicial protections separately. |\n| F14 | Rent, medical accounts and utilities | `excluded_with_reason` — C018 | Determine which obligations are NCA credit agreements, statutory municipal/service obligations or ordinary contracts, and their distinct remedies. |\n| F15 | Maintenance/support, fines and criminal/public obligations | `excluded_with_reason` — C018, C021 | Establish special statutory debt/collection and non-discharge regimes; no private workout generalisation. |\n| F16 | Tax, government debt and priority claims | `excluded_with_reason` — C018, C021 | Read applicable revenue, collection, administrative and insolvency priority law; separate taxpayer from company/estate capacity. |\n| F17 | Financial, nonprofit and public assistance | `excluded_with_reason` — C005, C036 | Identify actual public assistance programmes, eligibility, service mandates, effective dates and responsible bodies without assuming a blanket free-service exception. |\n| F18 | Full NCA debt-review eligibility, forms, stays, timelines and order effects | `excluded_with_reason` — C006, C019, C038, C046 | Complete current §86/§87/regulation 24 and court/Tribunal procedural and subsequent-amendment analysis. |\n| F19 | Administration-order and insolvency/sequestration procedure, forms, costs, discharge and taxes | `excluded_with_reason` — C020–C021, C041 | Conduct a separate full statutory-solution study; present provider capacity here does not resolve debtor outcomes. |\n| F20 | Business-rescue company rights, votes, priority, rescue plan and costs | `excluded_with_reason` — C022, C042 | Read current Companies Act Chapter 6 and rules, including §138, in full. |\n| F21 | Foreign creditors, currency, governing law, jurisdiction, recognition, foreign assets and moving abroad — A098 | `excluded_with_reason` — C014, C031 | Conduct the independent A098 cross-border report by transaction and jurisdiction; this pass only flags remote-provider nexus. |\n| F22 | Sector-specific rules, professional conduct and actual contract terms | `excluded_with_reason` — C013, C028, C035, C056 | Obtain exact sector law/professional regulations and, if authorised later, actual mandates and contracts; none was privately obtained. |\n| F23 | Full legislative/source currentness across every relevant subject | `partial` — C025, C030, C032–C033, C043, C048–C049 | Build provision-specific repeal/amendment/commencement timelines using Gazette notices; distinguish publication, guidance and effective date. |\n| F24 | All other countries and South Africa as a complete country root — A097 | `excluded_with_reason` — C014, C052 | Independently research each country/remaining South African branch; no adoption or inference from foreign regimes. |\n\n### Geographic register — all nine provinces\n\nNCA §50’s national registration framework was read. Its reference to applicable provincial legislation must not be flattened into “all provinces cleared.” No province-specific enacted body, municipal by-law, licensing decision or court-division rule was opened and substantively assessed in this pass. Each province therefore remains `unresolved`, notwithstanding the national finding C052.\n\n| Province | Geographic status and claim | Exact next question; material not examined |\n| --- | --- | --- |\n| Eastern Cape | `unresolved` — C052 is national only | Do Eastern Cape operative provincial enactments or the actual municipality’s trade/advertising rules attach to a locally established debt-services business? Check official provincial gazettes and the municipality concerned; neither examined. |\n| Free State | `unresolved` — C052 national only | Are any operative Free State provincial consumer/business provisions relevant to the defined actor or its premises? Read enacted text and effective dates; municipal rules unexamined. |\n| Gauteng | `unresolved` — C052 national only | Does an actual Gauteng establishment or targeted activity engage provincial business regulation or relevant municipal rules in addition to NCR categories? No such legislation read. |\n| KwaZulu-Natal | `unresolved` — C052 national only | Which, if any, current KwaZulu-Natal provincial or applicable municipal requirements govern the specified commercial premises, solicitation or local operation? Official text unexamined. |\n| Limpopo | `unresolved` — C052 national only | Is there operative provincial or location-specific regulation attaching to the business model, and what is its exact statutory trigger? No provincial gazette/locality reviewed. |\n| Mpumalanga | `unresolved` — C052 national only | Does the provider’s actual establishment or service activity invoke provincial/local business rules beyond the national licences identified? Primary text not read. |\n| Northern Cape | `unresolved` — C052 national only | Are any relevant provincial enactments or actual municipality’s trade requirements triggered by the physical or remote operation? No official provincial/local body examined. |\n| North West | `unresolved` — C052 national only | Do North West provincial or municipal provisions add an applicable permission or condition for this exact business activity? No official text reviewed. |\n| Western Cape | `unresolved` — C052 national only | Is any operative Western Cape or relevant municipality-specific trade, business or advertising rule applicable to an identified office/service model? No enacted provincial/local provisions read. |\n\nThis register makes no claim that a province has a debt-settlement licensing power. Nor does it certify every court division, municipality, customary-law circumstance, professional practice rule or sector in a province.\n\n## Research process and self-check\n\nFocused research complete; acceptance heldResearcher assessment only\n\nVerification clock\n\nPacific\n\n26 Oct 2026\n\nApproximately 4:39 p.m. PDT at final time checkUTC\n\n26 Oct 2026\n\nApproximately 23:39 UTCSouth Africa\n\n27 Oct 2026\n\nApproximately 1:39 a.m. SASTThe source accesses occurred during this research session, not necessarily at the final clock minute. Baseline requested: 22 October 2026, America/Los_Angeles.### Official-source search and read bounds\n\nRepositories actually used included:\n\n- South African Government/Government Gazettes: `gov.za` enactments, ministerial regulations and notices.\n- Department of Justice: `justice.gov.za` statute compilations and 2026 collector regulations.\n- NCR: `ncr.org.za` public register navigation, registration guidance and reports.\n- dtic: `thedtic.gov.za` official presentations, legislative compilation, annual report and withdrawal statements.\n- SARB: `resbank.co.za` NPS Act text, directives and 2026 management-body transition.\n- FSCA, Council for Debt Collectors, LPC and CIPC: official category guidance and public verification entrances.\n\nRepresentative exact searches in the audit trail included:\n\n- `South Africa National Credit Act debt counsellor registration regulations 2026 NCR debt counselling fee notice`\n- `site:gov.za National Credit Act Amendment Act 7 2019 commencement proclamation 2026 debt intervention`\n- `site:resbank.co.za 2026 payment system management body 2 September 2026 directive third-party`\n- `site:ncr.org.za National Credit Regulations 2006 \"Further criteria for registration as a debt counsellor\" regulation 10`\n- `site:gov.za \"National Credit Regulations\" \"10. Further criteria\" \"debt counsellor\"`\n\nThe searches identified primary documents, but results and snippets were not promoted to operative law without opening the relevant body. The exact opened provisions and PDF indices are in S001–S037. No full national Gazette sweep, subscription citator, authenticated regulator account or private conditions library was available. The absence of a discovered proclamation or amendment is therefore an unresolved search result, not proof of nonexistence.\n\nNo published precedent was cited as a controlling holding because no underlying official general precedent or Tribunal decision was fully opened and analysed. NCR’s annual-report descriptions were treated as regulator reporting, not judicial findings independently verified for this assignment. No named person, debtor, business, licence, case or property was searched; no provider was contacted. No outside filing, fee, application, complaint, payment or publication occurred.\n\n### Arithmetic self-check\n\n| Check | Recalculation | Validity bound |\n| --- | --- | --- |\n| Dated counsellor components | R550 + R500 = R1,050 | S006, 2016; not a 2026 payable amount. |\n| Dated PDA components | R550 + R100,000 = R100,550 | S006, 2016; excludes other costs and does not prove registration. |\n| Hypothetical aggregate insurance comparator | R2,000,000 × 1 = R2,000,000 compensatory value | S004 reg10A(6), assumed qualifying aggregate exposure; not premium or policy approval. |\n| Separate PDA capital criterion | R5,000,000 | S004 reg10A(5); not added to application fees and not recharacterised as consumer funds. |\n\nNo settlement percentage, debtor savings, fee cap, calendar filing date or legal outcome was invented.\n\n### Material questions generated for the next specialist passes\n\n1. What legally counts as performing §86 functions rather than supporting a private agreement? Obtain the fully amended operative definition/regulation 10 and classify tightly bounded workflow examples.\n2. What does a legitimate debt-counselling business structure look like where only individuals hold NCR debt-counsellor registration? Resolve real permissible employee tasks, supervision, representation and any current NCR conditions.\n3. Are the 2006 threshold figures and 2016 registration amounts still operative? Trace every relevant Government Gazette amendment and effective date.\n4. Has any presidential proclamation brought Act 7 of 2019, or particular provisions, into operation? Read the proclamation itself and operative transitional rules; do not infer from the government Act listing.\n5. How exactly do current SARB third-party payment categories coexist with NCR PDA registration after the 2026 PSMB transition? Read updated NPS legislation, directives and designated categories.\n6. When does a debtor advocate become a regulated legal practitioner, FAIS intermediary, collector or money-transmission actor? Build discrete fact tests under each current enacted instrument, including exceptions.\n7. What are the current Companies Act §138, insolvency and magistrates’ court appointment rules? Confirm authority for each distinct statutory solution.\n8. Do province-specific rules matter for an actual establishment, advertisement or service? Investigate all nine through operative texts before clearing any geography.\n\n### Evidence-grounded HomeLoanWiki/SettleADebt opportunities\n\nThese are article/tool opportunities, not authorisation to publish:\n\n| Candidate | Specific useful reader decision | Evidence and required gate |\n| --- | --- | --- |\n| “Debt review or private negotiation?” | Identify whether a proposed service is asking for §86 debt review or merely arranging consent between debtor and creditor. | C001, C003, C005–C006, C038; show court/Tribunal limits and an explicit “classification requires agreement facts” branch. |\n| “Who is registered to do what?” | Explain the distinct NCR counsellor, PDA, collector, LPC, FSCA and statutory-appointment roles. | C001, C007, C010–C013, C023, C028, C056; link to official read-only status pages and avoid an endorsement badge. |\n| “Who receives my payment?” | Draw a factual funds-flow questionnaire with categories: creditor directly, registered PDA, independent payment service or purported administrator. | C007–C009, C029, C051; do not publish operational assurances until updated payment/client-money rules pass review. |\n| “Individual, business borrower or guarantor?” | Identify documents needed to distinguish principal consumer, company, surety and joint borrower. | C014–C018, C044; suppress any live numeric threshold until the notice chain is verified. |\n| Annotated §44 / §86 reader | Show exactly which statutory words create a registered-person function and which parts require later court/Tribunal action. | S001/S002; require amendment/commencement reconciliation and copyright-appropriate short extracts. |\n| Regulatory change watch | Monitor 2019 commencement, NCR registration rules/fees, threshold notices and SARB payment changes. | C025, C030, C032–C033, C043, C049; tracked official instruments, not unsourced “last updated” decorations. |\n\n### Publication and operational holds\n\nHold the following claims\n\n- “A South African private debt-settlement company requires exactly one named licence,” or “no licence is required.”\n- “Our company’s registered employee authorises every employee’s debt review.”\n- “A collector licence authorises debtor representation,” or “an attorney/accountant/charity is categorically exempt.”\n- “2019 debt intervention is currently available,” without the operative proclamation.\n- “R1 million is the current exemption threshold” or “R1,050/R100,550 is the 2026 registration price,” without completing subsequent-rule checks.\n- “Client money is safe because we have a trust account,” without the actual payment category, funds safeguards and independent authorisation.\n- “All nine provinces are cleared,” or “a foreign remote provider is automatically exempt.”\n- Any promise of creditor cooperation, settlement success, cancellation of debt, automatic judgment invalidity, secured release, credit-score change or tax treatment.\n\n### Researcher self-check and handoff disposition\n\n- Independent jurisdiction: South African enacted and regulator materials were used; no US debt-settlement/FDCPA/TSR/CROA concepts or assumptions from other-country reports were adopted.\n- Provider-perimeter distinction: Separate statutory debt review, private voluntary negotiation, creditor-side collection, legal/financial services, payment distribution and formal court/CIPC/Master appointments.\n- Entity/person distinction: Explicitly preserved throughout the claims and scenarios.\n- Consequential exceptions: Surviving statutory exceptions, business/guarantor/credit classifications, enactment-versus-commencement, historic fee notices and remote nexus are conditional or held where evidence is incomplete.\n- Numbers: Dated, reproduced and recomputed; no current-fee or debtor-price representation.\n- Primary evidence: Source rows identify opened bodies versus guidance, dated consolidation, discovery-only and failed retrievals.\n- Geography: All nine provinces remain open. No nationwide/local acceptance inferred.\n- Cross-border: A098 expressly held.\n- Model and mode: Work performed in regular Chat using available ordinary browsing. I did not invoke Deep Research or paid APIs. The interface did not expose a verifiable selected reasoning tier for this answer, so I make no claim to have switched to or used Pro.\n- Review status: This is researcher self-check only. The coordinator must independently reopen consequential provisions, verify the 2026 amendment/commencement chains, recompute any numbers reused, and reconcile individual coverage gaps.\n\nDisposition: `C_ZA PASS-01 — NARROW PROVIDER/AUTHORISATION RESEARCH SUBMITTED; MATERIAL CURRENTNESS AND NEXUS GAPS OPEN; A097/A098 AND BROAD SOUTH AFRICA ACCEPTANCE HELD.`\n\nEND C_ZA PASS-01\n\n","tables":[{"headers":[],"index":0,"links":[],"row_links":[[],[],[],[],[],[],[],[]],"rows":[["Activity","Initial authorisation conclusion","Claims"],["General, non-individualised budgeting education","Does not by itself establish that statutory debt counselling is being performed; any applicable adjacent law must still be tested","C001, C005"],["Individual statutory debt review under NCA s86","Requires an appropriately registered natural-person debt counsellor","C001–C004"],["Negotiating a voluntary creditor compromise outside statutory debt review","Not conclusively classified merely by the words “negotiation” or “settlement”; the actual acts, representations, debts and mandate control","C005, C006"],["Handling debt-review payments as a payment distribution agent","Separate NCR registration and statutory conditions apply","C007–C009"],["Collecting another person's debt for reward on the creditor's behalf","Potential Debt Collectors Act registration, subject to its definitions and exclusions","C010–C012"],["Charging for reserved litigation/document-preparation activities","Legal Practice Act restrictions apply when their precise predicates are met","C013"],["Sequestration, administration orders or business rescue","Distinct statutory processes with different actors and appointing authorities","C020–C022"]]},{"headers":[],"index":1,"links":[],"row_links":[[],[],[],[],[],[],[],[],[]],"rows":[["Activity or claim","Governing test and preliminary conclusion","Evidence"],["Teaching budgeting or publishing general information","The NCA's debt-counselling regulations define debt counselling by reference to the functions in NCA §86. General educational content alone is not established to be a §86 service. This is an activity-based distinction, not a general exemption from all laws.","C003, C005; S001 §86; S014 reg. 1"],["Paid individual advice and negotiating a voluntary compromise","No standalone, universally applicable “debt-settlement company” licence was established by the authorities reviewed. But that does not establish that every paid arrangement is unregulated: examine representations, actual §86 functions, reserved legal work, financial products, and payments separately.","C005–C006, C013, C028–C029"],["Taking a consumer through statutory debt review","A person providing the NCA debt-counsellor service must be individually registered with the NCR. An incorporated employer, agency or trade name does not inherit that person's status.","C001–C004, C024; S001 §§44, 47; S003"],["Receiving a debt-review payment and distributing it to creditors","Separate NCR payment-distribution-agent (PDA) registration applies to that service. A debt counsellor is prohibited by regulation from collecting and distributing consumers' money.","C007–C009, C026; S002 §12 inserting §44A; S004 regs. 10A, 11"],["Collecting a creditor's debt for reward","The Debt Collectors Act has its own definition, Council registration and exceptions. It is not a licence to represent the debtor in statutory debt review.","C010–C012, C037, C050; S007 §§1, 8, 25–26"],["Appearing or preparing documents where legal practice is reserved","The Legal Practice Act restricts defined paid court appearances, preparation of documents for court proceedings, use of professional titles, and acts reserved by other laws. It does not, on the text examined, reserve every form of non-litigation negotiation.","C013, C035; S009 §§24, 30, 33–34"],["Advising on or intermediating regulated financial products","FAIS is an activity-and-product test. It cannot be assumed to apply to every conversation about an unpaid loan; nor can a debt service that actually distributes or recommends covered financial products assume it falls outside FAIS.","C028, C047; S015, S025"],["Acting as an appointed administrator, trustee or business-rescue practitioner","Those are separate statutory capacities. A general negotiation mandate, company registration or debt-counselling credential does not create a court appointment, Master's appointment or CIPC practitioner licence.","C020–C022, C041–C042"]]},{"headers":[],"index":2,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Actor or structure","What must be established","Adverse branch"],["Commercial debtor-paid negotiation firm","Actual advice, debt-review representations, mandate, fee recipient and payment flow. No money-handling conclusion from the words “debt settlement.”","If it undertakes §86 services without the requisite individual registration, the NCA §44 restriction is engaged; other reserved activities can trigger their own laws. C002, C005, C013, C029"],["Registered individual debt counsellor","Individual NCR status, permitted conditions, relevant qualifications, ongoing eligibility and the actual person responsible for §86 work.","A credential does not authorise incompatible debt collection or personal collection-and-distribution of client repayments. C001, C009, C024"],["Debt-counselling company, employee or “representative”","Identity of each registered natural person; employer's actual role; which tasks employees perform; limited NCA §163 administrative agency.","An employee credential cannot turn the company into an individually registered debt counsellor; a general agency contract does not confer full §86 powers. C004, C024"],["Free adviser, charity, nonprofit or consumer organisation","Whether genuinely only educating/referring, or actually performing regulated work; whether money or indirect benefit changes hands.","No blanket exemption from §44, legal-practice restrictions or payment rules was verified for “free” or “nonprofit” status. C005, C036"],["Attorney, advocate or legal clinic","Admission, current practising enrolment, permitted practice form, actual mandate and any legal-clinic approval or supervision.","Professional status cannot substitute for separate NCA PDA registration or automatically grant every statutory debt-counselling capacity. C013, C035"],["Accountant or other adviser","Actual professional qualification and work; whether court-reserved acts, §86 work, FAIS products or payment functions are added.","“Accountant” is not a blanket statutory debt-review exemption. C013, C028, C036"],["Original creditor collecting its own claim","Ownership of the claim, identity of payee and agents, and underlying NCA credit-provider duties where applicable.","It is not automatically a third-party Debt Collectors Act collector; that does not eliminate credit or collection-law obligations. C010, C037"],["Debt purchaser, collection agency, servicer or creditor-side attorney","Assignment/factoring terms, for-reward collection, the actual principal, registered personnel and specific statutory attorney or factoring exceptions.","Buying overdue debt can itself fall within the statutory collector definition; Council registration does not authorise debtor-side debt review. C010–C012, C037"],["Referral or software-only platform","Whether referrals, neutral records or calculations are the whole service, or whether the platform actually advises, holds itself out as a statutory provider or controls money.","A software interface does not remove the legal character of the underlying human or automated service. C005, C055"],["Payment service/PDA","NCR PDA category and, where actual movement or processing triggers it, SARB national-payment-system law. Exact payer, payee, bank account, authority to instruct and receipt of funds matter.","Neither an NCR debt-counsellor registration nor a generic “trust account” claim proves payment permission. C007–C009, C026, C029–C030"],["Public agency adviser","Statutory departmental function, employment or appointment and service actually offered; no inferred transferable private authority.","A public information service cannot be assumed to license an unrelated commercial actor. C036"],["Court administrator, insolvency trustee, liquidator or business-rescue practitioner","Specific statutory office, court or Master's appointment, or CIPC professional licence and appointment where applicable.","Marketing oneself as an “administrator” does not establish a court order or legally appointed office. C020–C022, C041–C042"]]},{"headers":[],"index":3,"links":[],"row_links":[[],[],[],[],[],[],[],[],[]],"rows":[["Body","Established role for this gateway","Limits on what its register proves"],["National Credit Regulator (NCR)","Individual debt counsellors and separately registered PDAs under NCA §§44, 44A; registration conditions and public registrant information under Chapter 3.","Registration is category- and person-specific; no approval of a particular contract, settlement claim or fee is inferred. C001, C007, C023, C039"],["Council for Debt Collectors","Creditor-side collection registration under Debt Collectors Act §§8–12.","Not an NCR debt-review credential or permission to represent consumers. C010–C012"],["Legal Practice Council and courts","Practitioner enrolment/roll; admission and defined reserved legal functions; courts exercise their actual adjudicative powers.","Professional enrolment and a court order are different evidence. C013, C035"],["Financial Sector Conduct Authority (FSCA)","Licensing and oversight where FAIS-defined financial advice or intermediary services are actually supplied.","An FSP entry does not establish approval to provide every form of debt negotiation. C028, C047"],["South African Reserve Bank (SARB)","National payment-system law, directives and—in the September 2026 transition—the licensing/authorising/registration functions for NPS payment institutions previously handled through PASA's management structure.","Does not displace the NCR's distinct PDA category. C029–C030"],["Magistrates' Court","Debt-rearrangement adjudication under NCA §87 and administration-order appointments under Magistrates' Courts Act §74E.","Neither is created by a private representation agreement. C020, C038, C041"],["High Court and Master of the High Court","Insolvency sequestration proceedings and trustee appointment/security under Insolvency Act §§3, 6, 56–57.","An adviser or debt collector is not automatically a trustee. C021"],["Companies and Intellectual Property Commission (CIPC), company and court as applicable","Company registration is separate from licensed business-rescue-practitioner status; statutory business-rescue appointments follow their own process.","A CIPC incorporation record is not a business-rescue licence. C022, C042, C057"]]},{"headers":[],"index":4,"links":[],"row_links":[[],[],[],[]],"rows":[["Actual mandate","Initial statutory test","Important adverse branch"],["A. Debtor pays A to seek a reduced balance from a lender","Test whether A performs NCA debt-counselling functions or other separately regulated professional/payment acts.","A is not automatically a debt collector merely because it negotiates a debt; the Debt Collectors Act definition focuses on recovering qualifying debts owed to another for reward. [C003, C005, C010]"],["B. Creditor pays B to recover its outstanding accounts","Test Debt Collectors Act §§1, 8–10 for the actual person/entity and its applicable exception.","A collector registration does not confer NCR debt-counsellor status or the authority to represent the debtor. [C010–C012]"],["C. C purchases overdue claims and pursues payment","The amended collector definition expressly addresses qualifying overdue purchased debts and distinguishes certain factoring.","Do not conclude “owning the debt” always exempts the purchaser; inspect assignment date, debt status, purchase purpose and statutory exception. [C010, C037]"]]},{"headers":[],"index":5,"links":[],"row_links":[[],[],[],[],[]],"rows":[["Mechanism invoked","Capacity test","What a consultant cannot establish by contract alone"],["Magistrates’ court administration","The court’s statutory order and appointment of an administrator under Magistrates’ Courts Act §§74 and 74E; applicable qualification/security obligations. [C020, C041]","That a privately engaged payment manager already holds the court-appointed administrator’s powers."],["Sequestration or insolvent estate administration","Insolvency Act court order and the Master’s statutory appointment/security regime for a trustee. [C021]","That “insolvency consultant” or “trust-account holder” means appointed trustee."],["Company business rescue","Companies Act professional categories and licensing framework, plus appointment in the actual company proceeding. [C022, C042]","That a CIPC company registration or a consultant’s advertised rescue expertise is an actual practitioner appointment."],["NCA debt review","Registered individual counsellor and §86/§87 statutory process. [C001, C038]","That any private debt-negotiation contract is a court-sanctioned debt-rearrangement order."]]},{"headers":[],"index":6,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["ID and issuing source — full direct URL","Actual pinpoint and page identification","Version, status, scope and reading limit"],["S001 — Parliament, National Credit Act 34 of 2005, Justice-hosted enacted text. https://www.justice.gov.za/mc/vnbp/act2005-034.pdf","Definitions §1, application §§4–9, NCR §14, debt counsellors §§44–52, debt-review §§85–89. Relevant PDF P8–21, P23, P36–40, P59–62; Gazette printed-page correspondence not fully verified.","Opened 26 Oct 2026. Original enacted Act, not a complete current consolidated text. Applied with S002 and commencement qualifications; the original file alone cannot establish an unamended 2026 rule. Republic/covered credit/registered actors. \njustice.gov.za"],["S002 — Parliament, National Credit Amendment Act 19 of 2014, Government Gazette 37665. https://www.gov.za/sites/default/files/gcis_document/201409/37665gon389.pdf","Insertion of §44A, amended §86 and insertion of §163(1C), with changes to §89. Relevant PDF P5–6, P11–12, P14–15; the corresponding printed Gazette numeration was not independently reconciled for each passage.","Opened 26 Oct 2026. Enacted amending text, with major provisions commencing in March 2015; this research did not establish a complete provision-by-provision commencement table. Read only cited amendments. \ngov.za"],["S003 — National Credit Regulator (NCR), August 2022 debt-counselling media release. https://www.ncr.org.za/documents/Media%20release%20-%20Debt%20counselling%20Campaign(August)-Final.pdf","Advice on registered individual counsellors, debt review and payments: PDF P0–2; printed pagination not separately established.","Opened 26 Oct 2026. Official regulator explanation, not an enacted exemption or independent source of criminal liability. It does not establish a 2026 fee schedule. \nncr.org.za"],["S004 — Minister, National Credit Regulations amendment, Government Notice R202, GG 38557, 13 March 2015. https://www.gov.za/sites/default/files/gcis_document/201503/38557rg10382gon202.pdf","Regulation 10A(1)–(9): PDF P3–8, printed GG pp.8–13; amended regulation 11: PDF P11, printed GG p.16. Critical specific parts: 10A(3)(b)–(c), (5), (6), (7), (9)(f)–(g).","Opened and rechecked 26 Oct 2026. Final gazetted amendment governing NCR PDA registration and separation; further later amendments not exhaustively excluded. Reg10A(7) additionally requires no distribution for consumers of the applicant’s own debt-counselling business. Regulation 11 prohibits counsellors themselves from collecting/distributing consumer monies. \ngov.za\ngov.za\ngov.za"],["S005 — NCR, Requirements for Registration as a Payment Distribution Agent. https://ncr.org.za/documents/pages/PDA/Requirements%20for%20registration%20as%20a%20payment%20distribution%20agent.pdf","PDF P0–1, issuer document page numbers not independently established; institutional and capability requirements cross-check S004 reg10A.","Opened 26 Oct 2026. Undated administrative guide; useful confirmation that PDA is an entity category, not a general natural-person debt-counsellor endorsement. S004 controls over a conflicting guide. \nncr.org.za"],["S006 — Minister, prescribed application, registration and renewal amounts, Government Notice 514, GG 39981, 11 May 2016. https://www.gov.za/sites/default/files/gcis_document/201605/39981gon514.pdf","Amended Schedule 2 item 2: PDF P1 / GG p.7 (R550 application); item 3 Tables C and D: PDF P3 / GG p.9 (R500 debt counsellor; R100,000 PDA); item 4: PDF P4 / GG p.10 (R250 branch).","Opened/rechecked 26 Oct 2026. Final 2016 rule; complete subsequent supersession/fee update chain not certified. These are registration charges, not borrower debt-counselling or settlement fees. \ngov.za"],["S010 — NCR, Public Register navigation. https://ncr.org.za/register/index.html","HTML, registered/cancelled/lapsed debt-counsellor and PDA category paths; PDF index not applicable; opened page navigation rather than person/entity results.","Opened 26 Oct 2026. Official public lookup entry point; no named lookup performed and no particular registration established. \nncr.org.za"],["S011 — South African Government, National Credit Act legislative record. https://www.gov.za/documents/national-credit-act","HTML, Act title and enactment/commencement metadata; PDF index not applicable.","Opened 26 Oct 2026. Official discovery and legislative-context page, not a substitute for section text and amendment commencement. \nSouth African Government"],["S012 — Parliament, National Credit Amendment Act 7 of 2019, GG 42649 alternative official Gazette copy. https://www.gov.za/sites/default/files/gcis_document/201908/42649gon1081.pdf","New debt-intervention provisions including §86A: PDF P14–16; §31 transition and §32 commencement: PDF P40 / GG p.42.","Opened/rechecked 26 Oct 2026. Enacted 2019 amending Act whose §32 requires presidential proclamation. No operative 2026 proclamation was established here. Therefore its proposed inserted debt-intervention pathway is not represented as in force. Government’s separate Act listing was also consulted. \ngov.za\ngov.za"],["S013 — Department of Trade, Industry and Competition (dtic), Debt Review presentation. https://www.thedtic.gov.za/wp-content/uploads/Debt-Review.pdf","Statutory-role process discussion: PDF P6–8; slides have their own visible sequence, not Gazette pages.","Opened 26 Oct 2026. Official educational presentation distinguishing registered natural-person debt counsellor from juristic PDA; describes practice but does not independently enact qualifications, fees or court outcomes. \nthedtic.gov.za"],["S014 — Minister, original National Credit Regulations, Government Notice R489, GG 28864 (2006). https://www.gov.za/sites/default/files/gcis_document/201409/28864.pdf","Regulation 1 definition of debt counselling, PDF P7 / GG approximately p.10; full operative regulation 10 text was not successfully re-opened in this pass.","Partially opened 26 Oct 2026. Original regulation; must be layered with 2015 amendments and later notices. Later attempts at the full source returned internal errors, so its qualification specifics remain partly unresolved. \ngov.za"],["S023 — Minister, credit-agreement threshold notice, Notice 713, GG 28893 (2006). https://www.gov.za/sites/default/files/gcis_document/201409/28893.pdf","Notice paragraphs 2–3: PDF P0 / printed GG p.3; R1 million juristic-person threshold and R15,000/R250,000 agreement-class thresholds.","Opened 26 Oct 2026. Official 2006 figures, not demonstrated to be the last legally operative amounts in Oct 2026; the relevant NCA classification tests remain separate. \ngov.za"],["S024 — NCR, Requirements for Registration as a Debt Counsellor. https://ncr.org.za/documents/pages/compliance&reports_cp/Requirements%20for%20registration%20as%20a%20debt%20counsellor.pdf","PDF P0–1; course, education, experience and an older “R100” amount. No dependable date in the document.","Opened 26 Oct 2026. Undated/outdated guide: its R100 is inconsistent with S006’s subsequent R500. It is not evidence that R100 is a current payable registration charge. \nncr.org.za"],["S029 — dtic, dated consolidation of National Credit Act. https://www.thedtic.gov.za/wp-content/uploads/National_Credit_Act34of2005.pdf","Consolidated §44/§86 framework and amendment markers: relevant PDF P35–40 and P75–79; internal printed-page alignment varies with layout.","Opened 26 Oct 2026. Dated compilation useful for tracing older amendments, not a 2026-certified consolidation. Its notes were not used as proof that no later proclamation exists. \nthedtic.gov.za"],["S035 — NCR Annual Report 2024/25, published through dtic. https://www.thedtic.gov.za/wp-content/uploads/NCR-Annual-Report-2024_2025.pdf","Debt-counselling qualification discussion PDF P24; NCR compliance, PDA supervision and enforcement PDF P44–45, report printed pp.44–45 in Part B.","Opened 26 Oct 2026. Official regulator retrospective evidence: training expectations, compliance monitoring and that actual enforcement requires an adjudicative process. It reports two category-related Tribunal outcomes without this research opening either underlying decision. Historical programme description, not proof of all 2026 criteria. \nthedtic.gov.za"]]},{"headers":[],"index":7,"links":[],"row_links":[[],[],[],[],[],[],[]],"rows":[["ID and issuing source — full direct URL","Actual pinpoint and page identification","Version, status, scope and reading limit"],["S007 — Parliament, Debt Collectors Act 114 of 1998, Justice-hosted annotated text. https://www.justice.gov.za/legislation/acts/1998-114.pdf","§1 definitions and exclusions PDF P0; registration §§8–10 PDF P2; register §12 PDF P3; offences/exemptions §§25–26 PDF P6. Printed internal statute page numbers broadly 1–7, not official GG pagination.","Opened 26 Oct 2026. Justice-hosted amended statute; amendment dates to be verified separately for a definitive consolidation. Covers collection for another, specified purchasers and actual statutory exceptions; not automatic authorisation for debtor-side debt review. \njustice.gov.za"],["S008 — Minister of Justice, 2026 amendments to Debt Collectors Regulations, Government Notice 7207, GG 54273, 6 March 2026. https://www.justice.gov.za/legislation/notices/2026/20260306-gg54273rg11951gon7207-DebtCollectors-Regulations.pdf","Regulation 11 substituted tariff: PDF P0–1 / printed GG pp.52–53. Distinct item caps include the stated R1,225 and R610 qualifications.","Opened 26 Oct 2026. Final 2026 Gazette notice. Creditor-side collection-cost tariff, not a debtor-paid negotiation fee schedule. Its application predicates and per-item distinctions must accompany any consumer-facing treatment. \njustice.gov.za"],["S009 — Parliament, Legal Practice Act 28 of 2014, Justice-hosted amended text. https://www.justice.gov.za/legislation/acts/2014-028.pdf","Admission and enrolment §§24 and 30, restrictions and practices §§33–34: PDF P11–15; internal compilation page numbering used, rather than Gazette p.","Opened 26 Oct 2026. Enacted/annotated text with provision-level commencement caveats. Does not establish that all ordinary debt explanations or all voluntary negotiations are reserved legal practice. Nor does attorney status confer NCR registration. \njustice.gov.za"],["S025 — Financial Sector Conduct Authority (FSCA), New Financial Service Provider guidance. https://www.fsca.co.za/New-Financial-Service-Provider/","HTML provider and representative regulatory route; PDF index not applicable.","Opened 26 Oct 2026. Regulator operational guidance; only relevant when actual service is a defined financial service involving an applicable product. Does not establish that ordinary debt settlement always needs an FSP licence. \nfsca.co.za"],["S026 — Council for Debt Collectors, active register entrance. https://www.cfdc.org.za/active-register/","HTML public register interface; PDF index not applicable.","Opened 26 Oct 2026. Official capacity-check route; no named collector was queried. A listing alone does not establish which particular engagement is authorised. \nDebt Collectors Register"],["S027 — Legal Practice Council, Search Practitioners interface. https://lpc.org.za/members-of-the-public/search-practitioners/","HTML public search instructions; PDF index not applicable.","Opened 26 Oct 2026. Official professional-capacity route; no named practitioner lookup conducted. Admission and a particular client mandate remain distinct. \nLegal Practice Council"]]},{"headers":[],"index":8,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["ID and issuing source — full direct URL","Actual pinpoint and page identification","Version, status, scope and reading limit"],["S015 — Parliament, Financial Advisory and Intermediary Services Act 37 of 2002, government-hosted original. https://www.gov.za/sites/default/files/gcis_document/201409/a37-020.pdf","§1 defined “financial product,” “advice” and “intermediary service”: PDF P3–4; §7 licensing identified, but its currently amended complete body and exemptions were not fully read. Printed enactment pagination not separately recorded.","Partially opened 26 Oct 2026. Original Act, not reliable alone as a 2026 consolidation. Consequently FAIS is a conditional activity/product screen, not a conclusion that debt negotiators all require FSCA registration. \ngov.za"],["S016 — Parliament/South African Reserve Bank (SARB), National Payment System Act 78 of 1998, SARB-hosted amended compilation. https://www.resbank.co.za/content/dam/sarb/what-we-do/payments-and-settlements/regulation-oversight/NPS%20Act.pdf","§7, regular acceptance of money/payment instructions for payment to a third party: PDF P9–10; binding directions §12: PDF P14. Printed statute-page numbering not independently mapped.","Opened 26 Oct 2026. SARB-hosted text incorporating significant amendments through approximately 2008; not certified fully consolidated through 2026. The amended §7 takes priority over an obsolete original. Do not equate NCA PDA permission with every required payment-system permission. \nresbank.co.za"],["S017 — SARB, Payment System Management Body transition page. https://www.resbank.co.za/en/home/what-we-do/payments-and-settlements/psmb","HTML sections describing 2026 functional transfer and 2 September 2026 high-value arrangement change; PDF index not applicable.","Opened 26 Oct 2026. Current regulator operational announcement; not an all-category licensing instrument. PASA’s earlier PSMB role cannot simply be carried forward unchanged. \nresbank.co.za\nresbank.co.za"],["S018 — Parliament, Magistrates’ Courts Act 32 of 1944, Justice-hosted amended text. https://www.justice.gov.za/legislation/acts/1944-032.pdf","Administration order §74: PDF P32; appointment §74E: PDF P35; account/funds-related §74J: PDF P37; §74P: PDF P38. Printed amended-act page numbers not separately verified.","Opened 26 Oct 2026. National statute for a distinct court-controlled procedure. Not evidence of a private firm’s appointment or universal consumer access to an order. \njustice.gov.za"],["S019 — Minister, Companies Regulations 2011, government-hosted Part C. https://www.gov.za/sites/default/files/gcis_document/201409/34239rg9526gon351c.pdf","Business-rescue practitioner licensing criteria, regulations 126–127, PDF P20–23; printed Gazette page number not independently reconciled.","Opened 26 Oct 2026. Final subordinate rules and qualification categories. The complete currently amended Companies Act §138 was not successfully opened; this source alone cannot decide a particular rescue appointment. \nPart C"],["S020 — Parliament, Insolvency Act 24 of 1936, Justice-hosted amended text. https://www.justice.gov.za/legislation/acts/1936-024.pdf","Debtor’s petition and court acceptance §§3, 6, PDF P3–5; trustee appointment/security/removal §§56–57, 60, PDF P31–34. Printed compilation page mapping not verified.","Opened 26 Oct 2026. Distinct court/Master legal capacity; not a voluntary settlement licence. The full estate process, discharge and priorities were not reviewed. \njustice.gov.za"],["S021 — dtic briefing to parliamentary portfolio committee, 12 November 2025. https://www.thedtic.gov.za/wp-content/uploads/re-Revised-Part-A-Regs.pdf","Label and description of withdrawn 2025 draft National Credit Regulations, especially PDF P1, P4–7, slide labels approximately 2 and 5–8.","Opened and rechecked 26 Oct 2026. Government explanation of withdrawal, not a statute. Crucial limit: relates to the August 2025 draft credit-information/SME amendments, not proof that every possible 2025 NCA rule or all future proposals were withdrawn. \nthedtic.gov.za"],["S022 — SARB, Directive 1 of 2007 on payments to third persons. https://www.resbank.co.za/content/dam/sarb/what-we-do/payments-and-settlements/regulation-oversight/D1_2007(ThirdParty).pdf","Third-party payer/beneficiary-agent directions and associated requirements, PDF P1–3; original directive pagination distinct from PDF index and not independently matched.","Opened 26 Oct 2026. SARB-issued directive, not general debtor-payment permission. Its status alongside the 2026 transfer of PSMB functions and subsequent instruments needs an updated NPS rule-by-rule check. \nresbank.co.za"],["S028 — Companies and Intellectual Property Commission (CIPC), business-rescue practitioner public information. https://www.cipc.co.za/?page_id=4745","HTML practitioner/licensing status listing with 7 October 2026 page update; PDF index not applicable.","Opened 26 Oct 2026. Public CIPC category/status information; no named practitioner was queried. A category listing is not itself an appointment to a particular company. \nCIPC"],["S030 — CIPC, Business Rescue Practitioner information. https://www.cipc.co.za/?page_id=4635","HTML descriptions of licence and appointment route, including its reference to Companies Act §138; PDF index not applicable.","Opened 26 Oct 2026. Competent registrar’s guidance. The precise currently amended statutory text and each practitioner category’s full conditions still require operative-act verification. \nCIPC"],["S033 — Minister, 2011 Companies Regulations forms appendix. https://www.gov.za/sites/default/files/gcis_document/201409/34239rg9526gon351i.pdf","Example CoR 126.1 application/licensing template, PDF P7–8; Gazette printed page not independently captured.","Opened 26 Oct 2026. An issued 2011 form only. It does not prove an individual licence, a current filing version or any appointment. No form submitted. \nPart I"]]},{"headers":[],"index":9,"links":[],"row_links":[[],[],[],[],[],[]],"rows":[["ID and issuing source — full direct URL","Actual pinpoint and page identification","Version, status, scope and reading limit"],["S031 — Minister, August 2025 draft NCA regulations, GG 53154. https://www.gov.za/sites/default/files/gcis_document/202508/53154rg11867gon6510.pdf","Draft text PDF P0–3, but substantive scanned text not reliably extracted or verified; printed Gazette pagination not confirmed.","Discovery/partly unread only, accessed 26 Oct 2026. Subsequently withdrawn draft as described more precisely in S021 and S036; never used as operative permission or an enforceable requirement. \ngov.za"],["S032 — Parliament, original National Payment System Act 78 of 1998. https://www.gov.za/sites/default/files/gcis_document/201409/a78-98.pdf","Original §7: PDF P4; printed enactment page not separately checked.","Opened 26 Oct 2026 as historical comparison; superseded wording. Do not cite its unamended §7 as the current payment-permission test; use S016 with further-currentness reservation. \ngov.za"],["S034 — South African Government, FAIS Act legislative listing. https://www.gov.za/st/documents/financial-advisory-and-intermediary-services-act","HTML Act/amendment metadata; PDF index not applicable.","Opened 26 Oct 2026. Confirms the need to account for legislation later than S015; metadata only, not a complete operative FAIS exemption/license rule. \nSouth African Government"],["S036 — dtic, Minister’s withdrawal statement, 12 September 2025. https://www.thedtic.gov.za/minister-tau-withdraws-the-national-credit-act-amendment-regulations/","HTML statement, paragraph beginning “The Minister … has withdrawn” and its description of the educational-institution credit-information issue; PDF index not applicable.","Opened 26 Oct 2026. Official explanation of a particular draft withdrawal, not an amendment or a general debt-counselling ruling. Read together with S021 rather than extending its subject matter. \nthedtic.gov.za"],["S037 — NCR, Guideline 001/2026 concerning clearance certificates through CBA platform, February 2026. https://www.ncr.org.za/documents/Guidelines/Guideline%20February%202026.pdf","Background and guidance purpose PDF P1; platform directions P2; transition P3. Printed guideline pages 1–3.","Opened 26 Oct 2026. Demonstrates that NCR procedures and issued guidance can change during 2026. Clearance-certificate filing requirements, timing and credit-reporting outcomes are deferred, not adopted into this authorisation gateway. \nncr.org.za"]]},{"headers":[],"index":10,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Claim","Exact bounded proposition, conditions, act and consequence","Primary evidence and limit"],["C_ZA-P01-C001","In South Africa, a person who provides or holds themselves out as authorised to provide NCA debt-counsellor services must be registered for that category; the NCR’s framework treats the debt counsellor as the registered natural person. Registering a company or employee in another category does not meet this requirement.","S001 §44(1)–(3); S002 amendments to §44; S003 PDF P0–2; S013 P6–7. Read currentness with amendments; precise individual status unsearched."],["C002","NCA §44(2) prohibits an unregistered person from offering, undertaking or holding themselves out as authorised for that statutory service. Consequences require the specific contravention/enforcement provisions; no underlying-debt cancellation follows solely from this prohibition.","S001 §44(2); S002; S035 P44–45. No particular enforcement case decided here."],["C003","The National Credit Regulations define “debt counselling” by reference to the services/functions in NCA §86. The statutory function, not a marketing adjective alone, determines the category.","S014 regulation 1, PDF P7; S001 §86. Full regulation 10 currentness remains partial."],["C004","An individual debt counsellor may use assistance within the limits of NCA §163(1C) for administrative functions; this is not a blanket delegation of statutory counselling authority to unregistered workers.","S002 inserted §163(1C), PDF P14–15. Which specific worker tasks are purely administrative requires facts."],["C005","Conditional inference: providing general budgeting education or facilitating a wholly private consensual workout is not automatically an application or determination under §86. But describing an activity as “voluntary” or “free” does not excuse actual §86 functions or other triggered regulatory conduct.","S014 regulation 1; S001 §§44, 86; S007 §1; S015 §1. No universal unregulated-debt-advice safe harbour established."],["C006","For a covered consumer’s statutory debt review, the registered counsellor’s assessment/recommendations and any competent Tribunal/court determination have defined roles under §§86–87; a private negotiator’s proposal is not itself that statutory order.","S001 §§86(6)–(8), 87; S002 amended §86. Complete procedural effects are deferred."],["C007","NCA §44A establishes a separately registered payment distribution agent category. A debt-counsellor credential alone is not PDA registration, and regulator guidance distinguishes a debtor paying directly from using an appropriate PDA.","S002 inserted §44A, PDF P5–6; S003 PDF P1–2. Other payment legislation may apply independently."],["C008","Under regulation 10A(3)–(4), a PDA applicant must satisfy specified organisational form, management, resource, competence, integrity and related tests; the listed structures include an incorporated company, close corporation or cooperative, plus the regulation’s stated board/experience conditions.","S004 PDF P3–5; S005 P0–1. Apparent differences between entity forms and prescribed board terminology require regulator-specific resolution; no application assessed."],["C009","National Credit Regulations regulation 11, as substituted in 2015, prohibits a debt counsellor from collecting and distributing consumers’ money. Acting through a properly distinct authorised PDA is a separate assessment, not an exception allowing the counsellor personally to do both.","S004 PDF P11 / GG p.16; reg10A(7), P6. Full safeguarding and payment-design requirements deferred."],["C010","The Debt Collectors Act §1 addresses qualifying recovery on behalf of another for reward, including specified recovery of overdue debts acquired for that purpose, subject to the text’s factoring and other exclusions. A debtor’s paid negotiator is not automatically in this category merely because creditors are contacted.","S007 §1, PDF P0. The actual mandate, assignment and compensation determine classification."],["C011","When someone meets the Debt Collectors Act’s operative collector definition and no statutory exception applies, §§8–10 require registration/capacity for the relevant collector and associated roles. A collector’s registration is not an NCR debt-counsellor licence.","S007 §§8–10, PDF P2; S001 §44. Entity and officer/employee facts must be checked."],["C012","Undertaking activity prohibited by Debt Collectors Act §8 can engage the §25 offence provision upon the legally required elements and process. This does not automatically void a debt, guarantee, judgment or security instrument.","S007 §§8, 25, PDF P2 and P6. No criminal finding or particular case examined."],["C013","Legal Practice Act §§24, 30, 33–34 separately govern admission/enrolment and specified reserved paid professional legal functions. A claimed attorney, advocate or corporate legal practice must meet the applicable provision and capacity rules; ordinary debt-related conversation is not proved categorically reserved merely by invoking the Act.","S009 §§24, 30, 33–34, PDF P11–15. Provision-level commencement and detailed activity classification remain open."],["C014","NCA §4 generally tests whether an arm’s-length credit agreement is made within, or has effect within, the Republic, subject to express limitations and exceptions. Neither residence nor loan label alone settles its application.","S001 §4(1)–(3), PDF P16–19. Agreement facts, foreign elements and amendment status still matter."],["C015","A juristic-person consumer receives materially different NCA treatment: §4 contains the threshold and large-agreement exclusions, while §6 disapplies specified NCA provisions to agreements with juristic consumers that remain otherwise covered. Therefore a company’s covered credit contract does not automatically admit its debts into individual §86 debt review.","S001 §§1, 4, 6, 9; S023 ¶¶2–3. Threshold amendment search incomplete; classify legal borrower first."],["C016","A credit guarantee/suretyship must be tested by NCA §§4(2)(c) and 8(5) against the underlying credit facility/transaction; a natural-person signatory’s name or the business use of funds does not alone prove consumer status or access to debt review.","S001 §§4(2)(c), 8(5), PDF P17–21. Terms and identities of principal and guarantor indispensable."],["C017","NCA §8 recognises secured/mortgage credit agreements, and §9 helps classify agreement size. Security type is not a universal inclusion or exclusion: the parties and operative §4 exceptions still have to be tested.","S001 §§4, 8(4), 9. Mortgage enforcement and property-law effects deferred."],["C018","Incidental credit, specified agreements/transactions and the express statutory categories are subject to NCA §§5 and 8(2) distinctions. An amount someone owes is not necessarily a covered “credit agreement” or a §86 debt-review item.","S001 §§5, 8(2). Product/debt-type-by-type analysis deferred."],["C019","A credit provider’s actual steps contemplated by NCA §130 can affect whether an agreement may be included in an §86 debt-review application under amended §86(2). A threat or collector call is not assumed to satisfy the statutory trigger.","S001 §§86(2), 130; S002 amendment to §86, PDF P11–12. Exact service, date and proceeding facts were not evaluated."],["C020","Magistrates’ Courts Act §§74 and 74E provides a separate administration-order mechanism in which the court exercises the relevant order/appointment powers. A voluntary contract with a payments company does not create that appointment.","S018 §§74, 74E, PDF P32, P35. Full order eligibility, asset and debt effects deferred."],["C021","Insolvency Act §§3, 6, 56–57 allocates distinct functions to the court and the Master/trustee appointment and security regime. A commercial negotiator is not a trustee merely because it uses insolvency terminology.","S020 cited sections, PDF P3–5, P31–33. No estate, appointment or full insolvency remedy analysed."],["C022","Business-rescue practitioner activity involves a CIPC licensing/professional-category framework under Companies Regulations 126–127, separately from the appointment required in the actual company proceeding. General CIPC incorporation does not equal such a licence or appointment.","S019 regs126–127, PDF P20–23; S030 HTML discussion of Companies Act §138. Current verbatim §138 and all licence conditions not independently reopened."],["C023","The NCR is the NCA registration/supervision authority for debt counsellors and PDAs, with national statutory registration and conditions; registration does not confer all other professional, collection or payment permissions.","S001 §§14, 44–52; S002 §44A; S035 P44–45. Province-specific qualification reserved under C052."],["C024","NCA §§46–47 and applicable regulations impose disqualification, education, experience and competence screens on relevant registrants. Holding a course certificate alone does not mean the NCR has registered an individual or that registration remains active.","S001 §§46–47; S002 corresponding amendments; S024 P0; S035 P24. Current full regulation 10/conditions chain unresolved."],["C025","Government Notice 514 in 2016 states R550 general registration application, R500 debt-counsellor category, R100,000 PDA category and a qualified R250 per branch. These amounts attach to the notice’s own category, item and period, not to a debtor’s settlement price.","S006 item 2, Tables C–D, item 4; PDF P1, P3–4 / GG pp.7, 9–10. Not certified current for 2026."],["C026","PDA regulation 10A(5) specifies R5 million minimum capital, evidenced as stated by a bank-guaranteed cheque; 10A(6) requires sufficient compensatory insurance measured against aggregate funds; 10A(7) separately requires independence and bars distributing funds for consumers of its own debt-counselling business.","S004 PDF P5–6 / GG pp.10–11. No specific 2026 licence or insurance contract reviewed."],["C027","The March 2026 Debt Collectors Regulations tariff sets specified recoverable collector-side charges and item-dependent maximums, including the Gazette’s qualified R1,225 and R610 figures. They are not a general permission to charge debtors those sums for settlement advocacy.","S008 substituted regulation 11, PDF P0–1 / GG pp.52–53. Exact charge item, number of acts and debt basis required before any calculation."],["C028","FAIS is potentially triggered when the actual act is defined financial advice/intermediary service concerning a defined financial product, with any applicable statutory exception; generic negotiation of an ordinary overdue account does not itself establish each element.","S015 §1, PDF P3–4; S025 provider guidance; S034 amendment listing. Partial: full currently amended §7 and exclusions not read."],["C029","Under the SARB-hosted amended NPS Act §7, regularly accepting funds/payment instructions from one person for payment to another requires classification against the subsection’s authorised alternatives and applicable §12 directives. NCA PDA status, a trust account, or a software interface alone does not settle NPS compliance.","S016 §§7, 12, PDF P9–10, P14; S022 Directive 1/2007, P1–3. NPS consolidation and 2026 directives need further checking."],["C030","SARB’s announced 2026 PSMB transition, including the 2 September 2026 handover, affects which body performs payment-system management functions. That institutional change does not itself authorise every payment business or automatically extinguish continuing instrument-specific obligations.","S017 regulator transition page; S016 §12. Exact present third-party provider category and any 2026 directive need separate determination."]]},{"headers":[],"index":11,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Claim","Exact bounded proposition, conditions, act and consequence","Primary evidence and limit"],["C031","NCA §4 has territorial rules relevant to a credit agreement involving a foreign creditor or South African effect; it does not alone settle the extraterritorial licensing status of a remotely operating debt adviser. Determine each service, targeted market, location, mandate and fund flow before asserting South African permission or exemption.","S001 §4(1)–(3); S015 §1; S016 §7. Partial nexus inference; foreign-assets/judgment questions reserved to A098."],["C032","National Credit Amendment Act 7 of 2019 §32 provides for commencement by presidential proclamation; enactment/publication in August 2019 is not the commencement event. A qualifying commencement proclamation had not been established in this research as at access on 26 Oct 2026.","S012 §§31–32, PDF P40 / GG p.42; S011 legislative metadata. This is unknown operative status, not a claim that no proclamation exists."],["C033","The specific August 2025 draft NCA regulations concerning credit-information reporting, including the contested education/SME issue, were withdrawn according to dtic’s September statement and November parliamentary briefing. They cannot supply a binding 2026 permission requirement.","S021 PDF P1, P4–7; S036 12 Sep 2025 statement. Scope limited to that draft; no general claim about other NCA rules."],["C034","The consequences for an unlawful credit agreement under amended NCA §89, including amended judicial treatment, are a different question from a counsellor/negotiator’s registration breach. Nothing in the read rules makes provider misconduct automatically cancel the customer’s underlying debt, release security or erase a judgment.","S001 §89; S002 amendment to §89; S035 P44–45. Actual relief, standing, judicial findings and contractual effects not adjudicated."],["C035","Legal practice requires the relevant LPC admission/enrolment and valid entity/practice capacity under LPA §§24, 30, 34, with distinct conditions for legal-practice structures and qualifying clinics. A person’s professional title does not itself establish the actual engagement’s mandate.","S009 §§24, 30, 34, PDF P11–15; S027 public entry point. No professional searched."],["C036","Conditional negative finding: no categorical exemption from actual NCA §44 debt-counselling functions was established merely for a charity, consumer organisation, nonprofit, free service, accountant, attorney or other qualified person. The activity, statutory text and any specific exception must be tested independently.","S001 §44; S002 §163(1C); S007 §1; S009 §§33–34. Not a claim that no activity-specific exemption anywhere exists."],["C037","A creditor recovering its own claim is not automatically the same Debt Collectors Act actor as a person collecting an amount owed to another for reward; however the amended §1 expressly brings certain overdue debt purchasers into scope. A servicer’s mandate and assignment terms can move the result.","S007 §1; S001 §1 “credit provider” definitions. Actual purchase, factoring and remuneration facts required."],["C038","Statutory debt review proceeds through NCA §86 application/assessment and the paths to a competent Tribunal or court under §§86–87. A private creditor workout may exist without those statutory acts, but cannot claim their procedural status or outcome.","S001 §§86–87; S002 amended §86; S013 P6–8. Full eligibility, forms, effects and timelines deferred."],["C039","NCR’s public materials distinguish registered, cancelled and lapsed category records. A bare historic registration number does not establish present status, scope, employment, mandate, company authorisation, fee legality or creditor assent.","S010 public register entry point; S001 §§44–52. No live individual/entity search performed."],["C040","Under the 2016 notice only, R550 + R500 = R1,050 for the illustrated application/category components, and R550 + R100,000 = R100,550 for the illustrated PDA components. Under regulation 10A(6), a hypothetical R2,000,000 aggregate amount collected for distribution yields an equivalent R2,000,000 illustrative compensatory value; R5,000,000 capital remains separate.","S006 item 2, Tables C–D; S004 reg10A(5)–(6). Arithmetic correct for stated assumptions, not 2026 fees, actual insurance suitability, consumer cost or debt reduction."],["C041","For magistrates’ administration, the court appoints the administrator under §74E, subject to statutory eligibility/security criteria. Custody and accounting are not established simply by accepting client funds; §74J has distinct administrator duties.","S018 §§74E, 74J, PDF P35, P37. Whether a particular officer qualifies requires order and role documents."],["C042","For company business rescue, CIPC licensing/category and actual company/court appointment are separate predicates. The professional status of one consultant does not automatically vest authority in their entire company or every employee.","S019 regs126–127; S030; S028. Current verbatim Companies Act §138 and specific appointment not verified."],["C043","The 2006 official threshold notice contains R1,000,000 for the specified juristic-person §4 threshold and R250,000 for the large-agreement classification, alongside R15,000 small/other categories. These figures are historically sourced, not conclusively verified as current on 26 Oct 2026.","S023 ¶¶2–3, PDF P0 / GG p.3; S001 §§4, 9. Must check later operative notices before publishing a current eligibility cutoff."],["C044","Joint signatures, a director’s signature, personal suretyship, borrower identity and guarantee status are distinct classification facts under NCA definitions/§§4 and 8. None alone establishes whose credit agreement is subject to §86 review.","S001 §§1, 4, 8, 86. Contract-specific inference; no assumption that joint borrowing and suretyship are legally identical."],["C045","The enacted 2019 debt-intervention amendments must not be advertised as an operating statutory benefit unless their proclamation, commencement and presently operative procedures are independently demonstrated.","S012 §32; S011 legislative metadata. Publication hold, not determination of permanent noncommencement."],["C046","NCA §86(5) addresses good-faith participation within statutory debt review; it must not be transformed into a promise that an ordinary private negotiator can compel a creditor to reduce principal or accept a particular workout.","S001 §86(5); S002 §86 amendments. No actual creditor response or settlement agreement reviewed."],["C047","An FSCA-authorised financial-services provider and any legally relevant representative have a permission framework only to the extent the actual FAIS product and activity engage it; FSP/representative status is not a universal substitute for NCR, collector or court appointment.","S015 §1, §7 (partial); S025 FSCA route; S034 amendment metadata. FAIS current full amended body and category detail unresolved."],["C048","NCA §44(3), §47 and regulation 10 impose an education/competence inquiry for individual debt-counsellor registration. NCR’s 2024/25 report identifies an approved course and describes its then-current short course as 10 days; a possible new occupational qualification was still under development then.","S001 §§44(3), 47; S024 P0; S035 P24. Historical course description is not a certified October 2026 qualification rule."],["C049","An older, undated NCR guide states R100, conflicting with the later official 2016 R500 category. Chronology and instrument type mean the guide cannot displace the gazetted notice; neither establishes the full 2026 amendment chain.","S024 P1 versus S006 Table C, PDF P3 / GG p.9. Explicit source conflict; live fee remains unverified."],["C050","Debt Collectors Act §26 provides for a ministerial exemption mechanism with its statutory conditions; it does not create an automatic exemption simply because the actor is nonprofit, philanthropic, professionally qualified or charges the debtor nothing.","S007 §26, PDF P6. Any specific valid exemption instrument and its beneficiary were not investigated."],["C051","PDA regulation 10A(5)–(9) has its own bank-guaranteed-cheque capital evidence, indemnity, independent-business and payment-account duties, including collection into a bank trust account and distribution/reporting requirements. These duties attach to the regulated PDA, not every business describing itself as a trustee.","S004 reg10A(5)–(9), PDF P5–8 / GG pp.10–13. Client-money compliance, regulatory conditions and payment permissions deferred."],["C052","NCA §50 addresses effect of NCR registration across the Republic subject to applicable provincial legislation. This is not proof that the laws of all nine provinces, courts, municipalities or specialised sectors have been examined.","S001 §50. Each province has an unresolved geographic research row below."],["C053","NPS Act §12 supplies statutory authority for applicable payment-system directives; an actor must first fall within the direction’s defined scope, and any adverse consequence requires its actual operative predicate.","S016 §12, PDF P14; S022 Directive 1/2007 P1–3. No blanket claim of a criminal offence for every unregistered “payment administrator”; current 2026 instruments remain to be checked."],["C054","A registered individual’s use of an employee or assistant does not let that employee perform every statutory §86 function under the individual’s number. NCA §163(1C)’s administrative task allocation and the actual performed functions decide the boundary.","S002 §163(1C), PDF P14–15; S001 §44. Individual staffing agreements and task logs unexamined."],["C055","Pure referrals, educational software and calculation tools are conditionally distinct from personalised statutory counselling, collecting on a creditor’s mandate and controlling consumer payments. If implementation or compensation changes the function, reclassify it.","S001 §§44, 86; S007 §1; S015 §1; S016 §7. Activity-based inference; no safe harbour for all lead generators/software suppliers established."],["C056","Public NCR, collector, LPC and CIPC registers are read-only category/status checks, not evidence of a particular service contract, debt-owner authority, consumer consent, fund safeguarding, creditor settlement or legal outcome.","S010, S026–S028 official interfaces; S001 §44; S007 §8; S009 §30. No named searches; results must be time-stamped if later obtained."],["C057","Ordinary CIPC entity incorporation does not automatically grant an individual’s NCR debt-counsellor registration, a juristic PDA registration, an FSCA permission or a business-rescue practitioner appointment. Each follows its own statutory actor/category.","S001 §44; S004 reg10A; S015 §1 and conditional §7; S019 regs126–127; S030. Company-specific documents absent; current FAIS and rescue amendment checks pending."]]},{"headers":[],"index":12,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Row","Material question and finding location","Status and exact claim IDs","Missing evidence / next focused action"],["A01","General advice/budgeting versus statutory debt counselling. Core activity comparison; Scenarios 1–2.","partial — C001, C003, C005, C036","Test the particular personalised assessment, recommendations, marketing and any other professional rules; do not create a categorical education exemption."],["A02","NCR debt-counsellor registration and holding out. Core provider table; Scenario 1.","answered — C001, C002, C004","For any later actual actor, verify individual status/date and real task allocation; no lookup authorised here."],["A03","Voluntary creditor negotiation, remission, repayment arrangements. Core comparison; Scenario 3.","partial — C005, C006, C038, C046","Resolve legal-practice, collection, mandate and funds-flow triggers; no unconditional settlement right found."],["A04","Payment collection/distribution boundary. Actor/authority findings; Scenarios 1 and 6.","partial — C007–C009, C026, C029, C051","Reopen fully updated NPS law, directives, individual PDA conditions and client-funds rules; those substantive protections remain deferred."],["A05","Natural person, sole trader and juristic person/business borrower. Credit-classification findings; Scenario 5.","partial — C014, C015, C043","Apply definitions to each actual agreement; establish 2026 threshold notice chain and sole-trader contracting capacity."],["A06","Guarantor, surety, joint borrower and director signature. Scenario 5.","partial — C016, C044","Read actual borrower/guarantee/security instruments; review precise current guarantee and joint-application rules."],["A07","Secured/mortgage versus incidental/other debts. Credit classification; Scenario 5.","partial — C017, C018","Product-by-product coverage and special remedies deferred; no all-debt debt-review claim."],["A08","Creditor’s own account versus third-party collector/purchaser. Scenario 3.","partial — C010–C012, C037, C050","Specific assignment, factoring, remuneration, creditor mandate and applicable exemption must be read."],["A09","Attorney/professional and FAIS perimeter. Actor matrix; Scenario 2.","partial — C013, C028, C035, C047","Read full currently amended FAIS §7/exemptions; classify reserved legal activity and effective LPA sections."],["A10","2026 amendment/commencement/transitional screen. Temporal findings and source register.","partial — C032, C033, C045","Obtain official full proclamation/amendment chains for 2019 debt intervention, NCA regulations, thresholds, FAIS and NPS."],["A11","Unauthorized-activity consequences. Registration findings; Scenario 1.","partial — C002, C012, C034, C053","Pin each violation to current element, enforcement body and actual remedy. No automatic debt/security/judgment extinction."],["A12","Commercial company/CIPC/trade name versus regulatory permissions. Actor/authority findings; Scenario 6.","answered — C001, C008, C022, C057","In a later real examination match separately each permission to the correct individual/entity and effective date."],["A13","Foreign remote offering/advertising/nexus. Scenario 4.","unresolved — C014, C029, C031","Read targeted NCA cross-border, relevant professional, payments, establishment and advertising rules for actual country/service/funds facts."],["A14","Formal debt review versus debt intervention. Statutory comparison.","partial — C032, C038, C045","Obtain and read an operative presidential proclamation (if any) and all associated regulations; no current benefit represented."]]},{"headers":[],"index":13,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Row","Actor and finding location","Status and exact claim IDs","Missing evidence / next focused action"],["B01","Commercial debtor-paid negotiator — Scenarios 1 and 3; activity matrix.","partial — C003, C005, C028","Determine whether the firm crosses §86, legal-practice, regulated product or money-handling boundaries in the exact engagement."],["B02","Personally registered NCR debt counsellor — Scenario 1.","answered — C001–C004, C024","Individual status/conditions not actually checked; identify which substantive tasks are performed."],["B03","Debt-counselling company, employees and representatives — Scenarios 1–2.","partial — C004, C054, C057","Obtain actual task chart, employment/agency authority, named registration and relevant conditions if authorised in later work."],["B04","Free/nonprofit/charity/consumer organisation — Scenario 2.","partial — C005, C036, C050","Test true activity, donations, indirect benefit and any expressly issued exemption; no blanket nonprofit exception."],["B05","Attorney and advocate — professional actor findings.","partial — C013, C035, C036","Read applicable professional practice/admission rules and precise reserved service, mandate and practice structure."],["B06","Accountant/other professional — Scenario 2.","partial — C005, C028, C036","Identify profession-specific statute, actual legal/financial advice and remuneration before claiming an exemption or additional authorisation."],["B07","Creditor recovering its own claim — Scenario 3.","partial — C010, C037","Separate ownership and collection for another; check credit-provider/NCA duties in a later conduct pass."],["B08","Debt collector or collection company/personnel — Scenario 3.","partial — C010–C012, C027, C050","Apply registration/exceptions to each statutory role; current fee tariff is not debtor-side advocacy permission."],["B09","Debt purchaser and servicer — Scenario 3.","partial — C010, C037","Read assignment, overdue status, acquisition purpose, factoring exception and servicing mandate."],["B10","Referrer, lead generator or software-only supplier — activity findings.","partial — C005, C055","Examine workflow, who decides/communicates proposals, compensation and whether money or client mandates pass through the intermediary."],["B11","PDA and staff — capacity findings.","partial — C007–C009, C026, C051","Operational category substantially identified; actual employee qualifications, full conditions and funds protection not cleared."],["B12","Public adviser/public authority — authority matrix.","partial — C023, C036, C038","Read precise statutory public-office functions/agency mandate. Official status alone is no blanket exception for outside commercial functions."],["B13","Court administrator — Scenario 6.","partial — C020, C041","Actual court appointment/order, qualifications and security; full administration-order procedure deferred."],["B14","Trustee, liquidator or estate officer — Scenario 6.","partial — C021","Insolvency trustee body and Master read; separate company-liquidator appointment and operative statutory powers require a focused reading."],["B15","Business-rescue practitioner — Scenario 6.","partial — C022, C042, C057","Obtain current Companies Act §138 body, CIPC conditions and actual appointment route."],["B16","Direct fee/indirect commission/benefit — Scenarios 2–3.","partial — C005, C010, C028, C036, C055","Read compensation arrangements and match statute-specific “reward,” advice/intermediation and professional tests; consumer fee rules deferred."],["B17","Qualification, fitness, resources and training — NCR/DC/PDA findings.","partial — C008, C024, C026, C048","Current complete regulation 10 and individual conditions; verify dated 2024/25 qualification description against any later final rules."],["B18","Nonprofit, professional, employment and ministerial exceptions — Scenario 2.","partial — C004, C036, C050, C054","Locate actual exemption instrument or express applicable provision, with its beneficiary and scope; no global exception established."]]},{"headers":[],"index":14,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Row","Authority or requirement; finding location","Status and exact claim IDs","Missing evidence / next focused action"],["COV-C01","NCR registers/supervises NCA debt counsellors and PDAs — authority matrix.","answered — C001, C007, C023, C039","Actual status/conditions to be verified only if a later authorised named check is requested."],["COV-C02","National Consumer Tribunal/court statutory decision roles — Scenario 1, §86 pathway.","partial — C006, C038, C046","Proceeding-specific jurisdiction, application, effect, standing and judicial orders deferred."],["COV-C03","Council for Debt Collectors — Scenario 3.","answered — C010–C012, C056","Actual role and registration not searched; current exceptions/conditions require case facts."],["COV-C04","Legal Practice Council — professional route.","partial — C013, C035, C056","Current admission/practice rules and any clinic-specific permission in actual transaction."],["COV-C05","FSCA/FSP/representative route — authority matrix.","partial — C028, C047","Read current full FAIS text, defined product schedule, FSP category, representative and exemptions."],["COV-C06","SARB/NPS, PSMB transition and other participant requirements — payment authority.","partial — C029, C030, C053","Full post-2026 operative NPS text/directives and classification of actual provider/payment operations."],["COV-C07","Court/Master/CIPC appointments — Scenario 6.","partial — C020–C022, C041–C042","Verify current Companies Act and each actual appointment instrument, not just a professional register."],["COV-C08","CIPC incorporation versus specialist authorisation — company boundary.","answered — C022, C057","Any actual company’s category, licence and practitioner identity require separate checks."],["COV-C09","NCR individual and PDA entity/capacity differentiation — authority matrix.","answered — C001, C007–C008, C054","Independent entity/individual status, representative tasks and registration conditions not checked."],["COV-C10","PDA regulatory capital/insurance — quantitative Example B.","partial — C026, C040, C051","Actual policy wording, aggregate exposure, legally sufficient cover, current conditions and financial-resource evidence."],["COV-C11","Application/registration/branch/periodic charges — Examples A–B.","partial — C025, C040, C049","Full current fee amendment chain and any current renewal/agency tariff; the 2016 example remains dated."],["COV-C12","Foreign operation/recognition/establishment — Scenario 4.","unresolved — C031, C057","Specific foreign-to-South-Africa statutory nexus, professional recognition, permanent establishment and advertised service tests."],["COV-C13","National registration effect versus provinces/locality — geographic register below.","partial — C023, C052","Separate operative provincial/local law research in all nine provinces; no invented provincial debt-counsellor licence."]]},{"headers":[],"index":15,"links":[],"row_links":[[],[],[],[],[],[],[],[],[]],"rows":[["Row","Verification subject and finding location","Status and exact claim IDs","Missing evidence / next focused action"],["D01","Official public registration/status categories — five-step verification workflow.","answered — C039, C056","Actual named search deliberately not performed; future lookup must preserve query date, category and restrictions."],["D02","Professional enrolment and statutory appointment — workflow; Scenario 6.","partial — C035, C041–C042, C056","Current practising status, actual court/Master/CIPC appointment and any limits; no actual person checked."],["D03","Minimum documentary classification packet — workflow and all scenarios.","answered — C014–C018, C031, C037, C044, C055–C057","Collect only if separately authorised later: agreements, capacity, services, remuneration, mandate, registration, funds flow."],["D04","Verification limits: permission ≠ contract/outcome — workflow.","answered — C034, C039, C056","Creditor assent and actual contract terms remain unavailable; no outcome promises."],["D05","Unauthorized acts and available legal consequences — Scenario 1.","partial — C002, C012, C034, C053","Exact element, version, regulator process and remedies; consumer-specific redress deferred."],["D06","Official general precedent/enforcement text — researcher limitations.","unresolved — C002, C012, C034","NCR annual report’s outcomes are summaries, not read primary Tribunal decisions. Future narrow official-judgment reading must record posture, holding, pinpoints and amendments. No full citator/nonexistence claim."],["D07","Private contracts, terms and consent — hypothetical documentation.","unresolved — C005, C037, C055–C056","No real service contract, assignment, consent, insurance policy or lender arrangement obtained; must not infer provisions."],["D08","Published template versus operative permission — S033 and workflow.","answered — C042, C056–C057","A 2011 issuer form proves its own published text/version only; not a current application or appointment."]]},{"headers":[],"index":16,"links":[],"row_links":[[],[],[],[],[],[],[],[],[]],"rows":[["Row","Narrow mechanism or output","Status and exact claim IDs","Missing evidence / next focused action"],["E01","Private voluntary workout versus §86/§87 debt review. Scenario 1 and 3.","answered — C005–C006, C038, C046","Actual eligibility, procedural protection and order effects deferred."],["E02","Registered counsellor, NCR, Tribunal and court roles. Statutory pathway.","partial — C001, C006, C023, C038","Detailed competence/appeals/procedure/status effects reserved."],["E03","Administration order as separate statutory route. Scenario 6.","partial — C020, C041","Full thresholds, eligible debts, forms, cost, security and post-order mechanics reserved."],["E04","Sequestration/insolvency as separate route. Scenario 6.","partial — C021","Full estate, priority, discharge, asset and tax rules reserved."],["E05","Company business rescue as separate route. Scenario 6.","partial — C022, C042","Currently amended §138 and full company rescue procedures reserved."],["E06","Six capacity/classification scenarios with adverse branches. Scenarios 1–6.","answered — C001–C009, C010–C022, C028–C031, C037–C044, C054–C057","Hypotheticals are conditional; no specific party/provider/borrower eligibility concluded."],["E07","Two historical financial examples and one aggregate-insurance check. Examples A–B.","answered for dated arithmetic; partial for present-day applicability — C025–C026, C040, C049, C051","Recheck 2026 fee and safeguard chain before anyone uses the figures in an application."],["E08","Complete debt-review and insolvency effects. Only narrow distinctions covered.","excluded_with_reason — C006, C018, C020–C022, C038","Separate full statutory-solution work; no broad-country A097 acceptance."]]},{"headers":[],"index":17,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Row","Deferred parent topic","Status and boundary claim IDs","Exact next focused research question"],["F01","Consumer fee earning and timing for debt counselling/private negotiation","excluded_with_reason — C025, C049","Which currently operative Act/regulation/NCR condition or valid guideline governs when each fee may be earned, charged or retained, for which service and person?"],["F02","Consumer fee caps, refunds and cancellation","excluded_with_reason — C025, C027, C049","Separate any operative debt-counselling fee guideline, contractual/private-service fees and collector-side tariff; read triggers, cancellation/refund conditions and amendment history."],["F03","Consumer contracts, disclosures, advertising and conduct","excluded_with_reason — C002, C005, C056","What currently applicable NCA, consumer-protection, professional and contract requirements govern the exact advertised service and its written terms?"],["F04","Client money, trust accounts and payment safeguarding","excluded_with_reason — C007–C009, C029, C051, C053","Map each account owner, beneficiary, custody interval, authorised payment category, reconciliations, indemnity, interest and permitted fund transfer under updated laws."],["F05","Private remedies and contract claims","excluded_with_reason — C012, C034, C056","What actual cause of action and remedy, against which actor, follows from proven facts? Distinguish provider liability from debt enforceability."],["F06","Regulatory redress, complaints and enforcement","excluded_with_reason — C002, C012, C023, C053","Identify current complaint channels, standing, jurisdiction, sanction elements, limitation and actual judicial/Tribunal remedies from operative primary law."],["F07","Full debt-product catalogue","excluded_with_reason — C014–C018","Classify every material credit and noncredit product, exclusions, contingent liabilities and special regimes, with current thresholds."],["F08","Collection, validation and debt disputes","excluded_with_reason — C010–C012, C027, C037","Read creditor/collector notices, proof, contested amounts, mandates and remedies under the exact applicable South African statute—not a foreign validation model."],["F09","Prescription, limitation and revival","excluded_with_reason — C012, C018, C034","Read the operative Prescription Act and debt-specific exceptions, acknowledgments, judgments and transitional rules."],["F10","Credit reporting, bureau disputes and clearance certificates","excluded_with_reason — C038, C045","Read current NCA §§70–72, regulations and 2026 NCR guidance, including operative filing and dispute procedures; S037 is not a completed rules audit."],["F11","Courts, service, default, judgments and enforcement","excluded_with_reason — C019–C021, C034","Identify court/Tribunal competence, process commencement, proper service, orders, remedies and applicable procedural rules before stating effects."],["F12","Enforcement exemptions, wages, bank accounts and assets","excluded_with_reason — C020–C021, C034","Read operative enforcement/protected-property legislation and applicable local forum rules for the type of debt/order."],["F13","Mortgage, other secured debts and repossession","excluded_with_reason — C016–C017, C021","Analyse real-security instruments, foreclosure/repossession processes, ownership, priority and judicial protections separately."],["F14","Rent, medical accounts and utilities","excluded_with_reason — C018","Determine which obligations are NCA credit agreements, statutory municipal/service obligations or ordinary contracts, and their distinct remedies."],["F15","Maintenance/support, fines and criminal/public obligations","excluded_with_reason — C018, C021","Establish special statutory debt/collection and non-discharge regimes; no private workout generalisation."],["F16","Tax, government debt and priority claims","excluded_with_reason — C018, C021","Read applicable revenue, collection, administrative and insolvency priority law; separate taxpayer from company/estate capacity."],["F17","Financial, nonprofit and public assistance","excluded_with_reason — C005, C036","Identify actual public assistance programmes, eligibility, service mandates, effective dates and responsible bodies without assuming a blanket free-service exception."],["F18","Full NCA debt-review eligibility, forms, stays, timelines and order effects","excluded_with_reason — C006, C019, C038, C046","Complete current §86/§87/regulation 24 and court/Tribunal procedural and subsequent-amendment analysis."],["F19","Administration-order and insolvency/sequestration procedure, forms, costs, discharge and taxes","excluded_with_reason — C020–C021, C041","Conduct a separate full statutory-solution study; present provider capacity here does not resolve debtor outcomes."],["F20","Business-rescue company rights, votes, priority, rescue plan and costs","excluded_with_reason — C022, C042","Read current Companies Act Chapter 6 and rules, including §138, in full."],["F21","Foreign creditors, currency, governing law, jurisdiction, recognition, foreign assets and moving abroad — A098","excluded_with_reason — C014, C031","Conduct the independent A098 cross-border report by transaction and jurisdiction; this pass only flags remote-provider nexus."],["F22","Sector-specific rules, professional conduct and actual contract terms","excluded_with_reason — C013, C028, C035, C056","Obtain exact sector law/professional regulations and, if authorised later, actual mandates and contracts; none was privately obtained."],["F23","Full legislative/source currentness across every relevant subject","partial — C025, C030, C032–C033, C043, C048–C049","Build provision-specific repeal/amendment/commencement timelines using Gazette notices; distinguish publication, guidance and effective date."],["F24","All other countries and South Africa as a complete country root — A097","excluded_with_reason — C014, C052","Independently research each country/remaining South African branch; no adoption or inference from foreign regimes."]]},{"headers":[],"index":18,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[]],"rows":[["Province","Geographic status and claim","Exact next question; material not examined"],["Eastern Cape","unresolved — C052 is national only","Do Eastern Cape operative provincial enactments or the actual municipality’s trade/advertising rules attach to a locally established debt-services business? Check official provincial gazettes and the municipality concerned; neither examined."],["Free State","unresolved — C052 national only","Are any operative Free State provincial consumer/business provisions relevant to the defined actor or its premises? Read enacted text and effective dates; municipal rules unexamined."],["Gauteng","unresolved — C052 national only","Does an actual Gauteng establishment or targeted activity engage provincial business regulation or relevant municipal rules in addition to NCR categories? No such legislation read."],["KwaZulu-Natal","unresolved — C052 national only","Which, if any, current KwaZulu-Natal provincial or applicable municipal requirements govern the specified commercial premises, solicitation or local operation? Official text unexamined."],["Limpopo","unresolved — C052 national only","Is there operative provincial or location-specific regulation attaching to the business model, and what is its exact statutory trigger? No provincial gazette/locality reviewed."],["Mpumalanga","unresolved — C052 national only","Does the provider’s actual establishment or service activity invoke provincial/local business rules beyond the national licences identified? Primary text not read."],["Northern Cape","unresolved — C052 national only","Are any relevant provincial enactments or actual municipality’s trade requirements triggered by the physical or remote operation? No official provincial/local body examined."],["North West","unresolved — C052 national only","Do North West provincial or municipal provisions add an applicable permission or condition for this exact business activity? No official text reviewed."],["Western Cape","unresolved — C052 national only","Is any operative Western Cape or relevant municipality-specific trade, business or advertising rule applicable to an identified office/service model? No enacted provincial/local provisions read."]]},{"headers":[],"index":19,"links":[],"row_links":[[],[],[],[],[]],"rows":[["Check","Recalculation","Validity bound"],["Dated counsellor components","R550 + R500 = R1,050","S006, 2016; not a 2026 payable amount."],["Dated PDA components","R550 + R100,000 = R100,550","S006, 2016; excludes other costs and does not prove registration."],["Hypothetical aggregate insurance comparator","R2,000,000 × 1 = R2,000,000 compensatory value","S004 reg10A(6), assumed qualifying aggregate exposure; not premium or policy approval."],["Separate PDA capital criterion","R5,000,000","S004 reg10A(5); not added to application fees and not recharacterised as consumer funds."]]},{"headers":[],"index":20,"links":[],"row_links":[[],[],[],[],[],[],[]],"rows":[["Candidate","Specific useful reader decision","Evidence and required gate"],["“Debt review or private negotiation?”","Identify whether a proposed service is asking for §86 debt review or merely arranging consent between debtor and creditor.","C001, C003, C005–C006, C038; show court/Tribunal limits and an explicit “classification requires agreement facts” branch."],["“Who is registered to do what?”","Explain the distinct NCR counsellor, PDA, collector, LPC, FSCA and statutory-appointment roles.","C001, C007, C010–C013, C023, C028, C056; link to official read-only status pages and avoid an endorsement badge."],["“Who receives my payment?”","Draw a factual funds-flow questionnaire with categories: creditor directly, registered PDA, independent payment service or purported administrator.","C007–C009, C029, C051; do not publish operational assurances until updated payment/client-money rules pass review."],["“Individual, business borrower or guarantor?”","Identify documents needed to distinguish principal consumer, company, surety and joint borrower.","C014–C018, C044; suppress any live numeric threshold until the notice chain is verified."],["Annotated §44 / §86 reader","Show exactly which statutory words create a registered-person function and which parts require later court/Tribunal action.","S001/S002; require amendment/commencement reconciliation and copyright-appropriate short extracts."],["Regulatory change watch","Monitor 2019 commencement, NCR registration rules/fees, threshold notices and SARB payment changes.","C025, C030, C032–C033, C043, C049; tracked official instruments, not unsourced “last updated” decorations."]]}],"claims":[{"claim_id":"C_ZA-P01-C001","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C_ZA-P01-C001","Exact bounded proposition, conditions, act and consequence":"In South Africa, a person who provides or holds themselves out as authorised to provide NCA debt-counsellor services must be registered for that category; the NCR’s framework treats the debt counsellor as the registered natural person. Registering a company or employee in another category does not meet this requirement.","Primary evidence and limit":"S001 §44(1)–(3); S002 amendments to §44; S003 PDF P0–2; S013 P6–7. Read currentness with amendments; precise individual status unsearched."},"raw_table_index":10,"coordinator_verification_status":"selected_body_or_arithmetic_supported_currentness_and_application_held","id_normalization":"Explicit fully-qualified raw identifier retained; removed redundant importer task prefix. Original raw cell unchanged.","coordinator_review":"C001 core registration proposition is supported by original NCA44. Its S002 amendments-to44 label is imprecise: selected2014 text inserts44A and addresses related provisions; it does not establish amendment of44 itself. Retain full currentness hold.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00","coordinator_pinpoint_annotation":"C001 core registration proposition is supported by original NCA44. Its S002 amendments-to44 label is imprecise: selected2014 text inserts44A and addresses related provisions; it does not establish amendment of44 itself. Retain full currentness hold."},{"claim_id":"C_ZA-C002","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C002","Exact bounded proposition, conditions, act and consequence":"NCA §44(2) prohibits an unregistered person from offering, undertaking or holding themselves out as authorised for that statutory service. Consequences require the specific contravention/enforcement provisions; no underlying-debt cancellation follows solely from this prohibition.","Primary evidence and limit":"S001 §44(2); S002; S035 P44–45. No particular enforcement case decided here."},"raw_table_index":10,"coordinator_verification_status":"selected_body_or_arithmetic_supported_currentness_and_application_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"},{"claim_id":"C_ZA-C003","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C003","Exact bounded proposition, conditions, act and consequence":"The National Credit Regulations define “debt counselling” by reference to the services/functions in NCA §86. The statutory function, not a marketing adjective alone, determines the category.","Primary evidence and limit":"S014 regulation 1, PDF P7; S001 §86. Full regulation 10 currentness remains partial."},"raw_table_index":10,"coordinator_verification_status":"traceability_and_explicit_limits_checked_remaining_primary_verification_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"},{"claim_id":"C_ZA-C004","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C004","Exact bounded proposition, conditions, act and consequence":"An individual debt counsellor may use assistance within the limits of NCA §163(1C) for administrative functions; this is not a blanket delegation of statutory counselling authority to unregistered workers.","Primary evidence and limit":"S002 inserted §163(1C), PDF P14–15. Which specific worker tasks are purely administrative requires facts."},"raw_table_index":10,"coordinator_verification_status":"selected_body_or_arithmetic_supported_currentness_and_application_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"},{"claim_id":"C_ZA-C005","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C005","Exact bounded proposition, conditions, act and consequence":"Conditional inference: providing general budgeting education or facilitating a wholly private consensual workout is not automatically an application or determination under §86. But describing an activity as “voluntary” or “free” does not excuse actual §86 functions or other triggered regulatory conduct.","Primary evidence and limit":"S014 regulation 1; S001 §§44, 86; S007 §1; S015 §1. No universal unregulated-debt-advice safe harbour established."},"raw_table_index":10,"coordinator_verification_status":"traceability_and_explicit_limits_checked_remaining_primary_verification_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"},{"claim_id":"C_ZA-C006","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C006","Exact bounded proposition, conditions, act and consequence":"For a covered consumer’s statutory debt review, the registered counsellor’s assessment/recommendations and any competent Tribunal/court determination have defined roles under §§86–87; a private negotiator’s proposal is not itself that statutory order.","Primary evidence and limit":"S001 §§86(6)–(8), 87; S002 amended §86. Complete procedural effects are deferred."},"raw_table_index":10,"coordinator_verification_status":"traceability_and_explicit_limits_checked_remaining_primary_verification_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"},{"claim_id":"C_ZA-C007","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C007","Exact bounded proposition, conditions, act and consequence":"NCA §44A establishes a separately registered payment distribution agent category. A debt-counsellor credential alone is not PDA registration, and regulator guidance distinguishes a debtor paying directly from using an appropriate PDA.","Primary evidence and limit":"S002 inserted §44A, PDF P5–6; S003 PDF P1–2. Other payment legislation may apply independently."},"raw_table_index":10,"coordinator_verification_status":"selected_body_or_arithmetic_supported_currentness_and_application_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"},{"claim_id":"C_ZA-C008","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C008","Exact bounded proposition, conditions, act and consequence":"Under regulation 10A(3)–(4), a PDA applicant must satisfy specified organisational form, management, resource, competence, integrity and related tests; the listed structures include an incorporated company, close corporation or cooperative, plus the regulation’s stated board/experience conditions.","Primary evidence and limit":"S004 PDF P3–5; S005 P0–1. Apparent differences between entity forms and prescribed board terminology require regulator-specific resolution; no application assessed."},"raw_table_index":10,"coordinator_verification_status":"selected_body_or_arithmetic_supported_currentness_and_application_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"},{"claim_id":"C_ZA-C009","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C009","Exact bounded proposition, conditions, act and consequence":"National Credit Regulations regulation 11, as substituted in 2015, prohibits a debt counsellor from collecting and distributing consumers’ money. Acting through a properly distinct authorised PDA is a separate assessment, not an exception allowing the counsellor personally to do both.","Primary evidence and limit":"S004 PDF P11 / GG p.16; reg10A(7), P6. Full safeguarding and payment-design requirements deferred."},"raw_table_index":10,"coordinator_verification_status":"selected_body_or_arithmetic_supported_currentness_and_application_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"},{"claim_id":"C_ZA-C010","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C010","Exact bounded proposition, conditions, act and consequence":"The Debt Collectors Act §1 addresses qualifying recovery on behalf of another for reward, including specified recovery of overdue debts acquired for that purpose, subject to the text’s factoring and other exclusions. A debtor’s paid negotiator is not automatically in this category merely because creditors are contacted.","Primary evidence and limit":"S007 §1, PDF P0. The actual mandate, assignment and compensation determine classification."},"raw_table_index":10,"coordinator_verification_status":"selected_body_or_arithmetic_supported_currentness_and_application_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"},{"claim_id":"C_ZA-C011","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C011","Exact bounded proposition, conditions, act and consequence":"When someone meets the Debt Collectors Act’s operative collector definition and no statutory exception applies, §§8–10 require registration/capacity for the relevant collector and associated roles. A collector’s registration is not an NCR debt-counsellor licence.","Primary evidence and limit":"S007 §§8–10, PDF P2; S001 §44. Entity and officer/employee facts must be checked."},"raw_table_index":10,"coordinator_verification_status":"selected_body_or_arithmetic_supported_currentness_and_application_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"},{"claim_id":"C_ZA-C012","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C012","Exact bounded proposition, conditions, act and consequence":"Undertaking activity prohibited by Debt Collectors Act §8 can engage the §25 offence provision upon the legally required elements and process. This does not automatically void a debt, guarantee, judgment or security instrument.","Primary evidence and limit":"S007 §§8, 25, PDF P2 and P6. No criminal finding or particular case examined."},"raw_table_index":10,"coordinator_verification_status":"selected_body_or_arithmetic_supported_currentness_and_application_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"},{"claim_id":"C_ZA-C013","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C013","Exact bounded proposition, conditions, act and consequence":"Legal Practice Act §§24, 30, 33–34 separately govern admission/enrolment and specified reserved paid professional legal functions. A claimed attorney, advocate or corporate legal practice must meet the applicable provision and capacity rules; ordinary debt-related conversation is not proved categorically reserved merely by invoking the Act.","Primary evidence and limit":"S009 §§24, 30, 33–34, PDF P11–15. Provision-level commencement and detailed activity classification remain open."},"raw_table_index":10,"coordinator_verification_status":"traceability_and_explicit_limits_checked_remaining_primary_verification_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"},{"claim_id":"C_ZA-C014","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C014","Exact bounded proposition, conditions, act and consequence":"NCA §4 generally tests whether an arm’s-length credit agreement is made within, or has effect within, the Republic, subject to express limitations and exceptions. Neither residence nor loan label alone settles its application.","Primary evidence and limit":"S001 §4(1)–(3), PDF P16–19. Agreement facts, foreign elements and amendment status still matter."},"raw_table_index":10,"coordinator_verification_status":"traceability_and_explicit_limits_checked_remaining_primary_verification_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"},{"claim_id":"C_ZA-C015","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C015","Exact bounded proposition, conditions, act and consequence":"A juristic-person consumer receives materially different NCA treatment: §4 contains the threshold and large-agreement exclusions, while §6 disapplies specified NCA provisions to agreements with juristic consumers that remain otherwise covered. Therefore a company’s covered credit contract does not automatically admit its debts into individual §86 debt review.","Primary evidence and limit":"S001 §§1, 4, 6, 9; S023 ¶¶2–3. Threshold amendment search incomplete; classify legal borrower first."},"raw_table_index":10,"coordinator_verification_status":"traceability_and_explicit_limits_checked_remaining_primary_verification_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"},{"claim_id":"C_ZA-C016","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C016","Exact bounded proposition, conditions, act and consequence":"A credit guarantee/suretyship must be tested by NCA §§4(2)(c) and 8(5) against the underlying credit facility/transaction; a natural-person signatory’s name or the business use of funds does not alone prove consumer status or access to debt review.","Primary evidence and limit":"S001 §§4(2)(c), 8(5), PDF P17–21. Terms and identities of principal and guarantor indispensable."},"raw_table_index":10,"coordinator_verification_status":"traceability_and_explicit_limits_checked_remaining_primary_verification_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"},{"claim_id":"C_ZA-C017","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C017","Exact bounded proposition, conditions, act and consequence":"NCA §8 recognises secured/mortgage credit agreements, and §9 helps classify agreement size. Security type is not a universal inclusion or exclusion: the parties and operative §4 exceptions still have to be tested.","Primary evidence and limit":"S001 §§4, 8(4), 9. Mortgage enforcement and property-law effects deferred."},"raw_table_index":10,"coordinator_verification_status":"traceability_and_explicit_limits_checked_remaining_primary_verification_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"},{"claim_id":"C_ZA-C018","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C018","Exact bounded proposition, conditions, act and consequence":"Incidental credit, specified agreements/transactions and the express statutory categories are subject to NCA §§5 and 8(2) distinctions. An amount someone owes is not necessarily a covered “credit agreement” or a §86 debt-review item.","Primary evidence and limit":"S001 §§5, 8(2). Product/debt-type-by-type analysis deferred."},"raw_table_index":10,"coordinator_verification_status":"traceability_and_explicit_limits_checked_remaining_primary_verification_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"},{"claim_id":"C_ZA-C019","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C019","Exact bounded proposition, conditions, act and consequence":"A credit provider’s actual steps contemplated by NCA §130 can affect whether an agreement may be included in an §86 debt-review application under amended §86(2). A threat or collector call is not assumed to satisfy the statutory trigger.","Primary evidence and limit":"S001 §§86(2), 130; S002 amendment to §86, PDF P11–12. Exact service, date and proceeding facts were not evaluated."},"raw_table_index":10,"coordinator_verification_status":"traceability_and_explicit_limits_checked_remaining_primary_verification_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"},{"claim_id":"C_ZA-C020","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C020","Exact bounded proposition, conditions, act and consequence":"Magistrates’ Courts Act §§74 and 74E provides a separate administration-order mechanism in which the court exercises the relevant order/appointment powers. A voluntary contract with a payments company does not create that appointment.","Primary evidence and limit":"S018 §§74, 74E, PDF P32, P35. Full order eligibility, asset and debt effects deferred."},"raw_table_index":10,"coordinator_verification_status":"traceability_and_explicit_limits_checked_remaining_primary_verification_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"},{"claim_id":"C_ZA-C021","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C021","Exact bounded proposition, conditions, act and consequence":"Insolvency Act §§3, 6, 56–57 allocates distinct functions to the court and the Master/trustee appointment and security regime. A commercial negotiator is not a trustee merely because it uses insolvency terminology.","Primary evidence and limit":"S020 cited sections, PDF P3–5, P31–33. No estate, appointment or full insolvency remedy analysed."},"raw_table_index":10,"coordinator_verification_status":"traceability_and_explicit_limits_checked_remaining_primary_verification_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"},{"claim_id":"C_ZA-C022","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C022","Exact bounded proposition, conditions, act and consequence":"Business-rescue practitioner activity involves a CIPC licensing/professional-category framework under Companies Regulations 126–127, separately from the appointment required in the actual company proceeding. General CIPC incorporation does not equal such a licence or appointment.","Primary evidence and limit":"S019 regs126–127, PDF P20–23; S030 HTML discussion of Companies Act §138. Current verbatim §138 and all licence conditions not independently reopened."},"raw_table_index":10,"coordinator_verification_status":"traceability_and_explicit_limits_checked_remaining_primary_verification_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"},{"claim_id":"C_ZA-C023","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C023","Exact bounded proposition, conditions, act and consequence":"The NCR is the NCA registration/supervision authority for debt counsellors and PDAs, with national statutory registration and conditions; registration does not confer all other professional, collection or payment permissions.","Primary evidence and limit":"S001 §§14, 44–52; S002 §44A; S035 P44–45. Province-specific qualification reserved under C052."},"raw_table_index":10,"coordinator_verification_status":"selected_body_or_arithmetic_supported_currentness_and_application_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"},{"claim_id":"C_ZA-C024","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C024","Exact bounded proposition, conditions, act and consequence":"NCA §§46–47 and applicable regulations impose disqualification, education, experience and competence screens on relevant registrants. Holding a course certificate alone does not mean the NCR has registered an individual or that registration remains active.","Primary evidence and limit":"S001 §§46–47; S002 corresponding amendments; S024 P0; S035 P24. Current full regulation 10/conditions chain unresolved."},"raw_table_index":10,"coordinator_verification_status":"traceability_and_explicit_limits_checked_remaining_primary_verification_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"},{"claim_id":"C_ZA-C025","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C025","Exact bounded proposition, conditions, act and consequence":"Government Notice 514 in 2016 states R550 general registration application, R500 debt-counsellor category, R100,000 PDA category and a qualified R250 per branch. These amounts attach to the notice’s own category, item and period, not to a debtor’s settlement price.","Primary evidence and limit":"S006 item 2, Tables C–D, item 4; PDF P1, P3–4 / GG pp.7, 9–10. Not certified current for 2026."},"raw_table_index":10,"coordinator_verification_status":"selected_body_or_arithmetic_supported_currentness_and_application_held","coordinator_review":"Pinpoint clarification:550 is item2; TablesC/D are introduced by item3; branch amount is item4. No change to dated amounts or application scope.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00","coordinator_pinpoint_annotation":"Pinpoint clarification:550 is item2; TablesC/D are introduced by item3; branch amount is item4. No change to dated amounts or application scope."},{"claim_id":"C_ZA-C026","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C026","Exact bounded proposition, conditions, act and consequence":"PDA regulation 10A(5) specifies R5 million minimum capital, evidenced as stated by a bank-guaranteed cheque; 10A(6) requires sufficient compensatory insurance measured against aggregate funds; 10A(7) separately requires independence and bars distributing funds for consumers of its own debt-counselling business.","Primary evidence and limit":"S004 PDF P5–6 / GG pp.10–11. No specific 2026 licence or insurance contract reviewed."},"raw_table_index":10,"coordinator_verification_status":"selected_body_or_arithmetic_supported_currentness_and_application_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"},{"claim_id":"C_ZA-C027","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C027","Exact bounded proposition, conditions, act and consequence":"The March 2026 Debt Collectors Regulations tariff sets specified recoverable collector-side charges and item-dependent maximums, including the Gazette’s qualified R1,225 and R610 figures. They are not a general permission to charge debtors those sums for settlement advocacy.","Primary evidence and limit":"S008 substituted regulation 11, PDF P0–1 / GG pp.52–53. Exact charge item, number of acts and debt basis required before any calculation."},"raw_table_index":10,"coordinator_verification_status":"selected_body_or_arithmetic_supported_currentness_and_application_held","coordinator_review":"Notice amends the regulation11 amount and substitutes AnnexB, not the whole regulation11.1225 has items1-7/capital predicates;610 belongs to item9 percentage cap. Existing conditional claim retained.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00","coordinator_pinpoint_annotation":"Notice amends the regulation11 amount and substitutes AnnexB, not the whole regulation11.1225 has items1-7/capital predicates;610 belongs to item9 percentage cap. Existing conditional claim retained."},{"claim_id":"C_ZA-C028","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C028","Exact bounded proposition, conditions, act and consequence":"FAIS is potentially triggered when the actual act is defined financial advice/intermediary service concerning a defined financial product, with any applicable statutory exception; generic negotiation of an ordinary overdue account does not itself establish each element.","Primary evidence and limit":"S015 §1, PDF P3–4; S025 provider guidance; S034 amendment listing. Partial: full currently amended §7 and exclusions not read."},"raw_table_index":10,"coordinator_verification_status":"traceability_and_explicit_limits_checked_remaining_primary_verification_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"},{"claim_id":"C_ZA-C029","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C029","Exact bounded proposition, conditions, act and consequence":"Under the SARB-hosted amended NPS Act §7, regularly accepting funds/payment instructions from one person for payment to another requires classification against the subsection’s authorised alternatives and applicable §12 directives. NCA PDA status, a trust account, or a software interface alone does not settle NPS compliance.","Primary evidence and limit":"S016 §§7, 12, PDF P9–10, P14; S022 Directive 1/2007, P1–3. NPS consolidation and 2026 directives need further checking."},"raw_table_index":10,"coordinator_verification_status":"traceability_and_explicit_limits_checked_remaining_primary_verification_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"},{"claim_id":"C_ZA-C030","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C030","Exact bounded proposition, conditions, act and consequence":"SARB’s announced 2026 PSMB transition, including the 2 September 2026 handover, affects which body performs payment-system management functions. That institutional change does not itself authorise every payment business or automatically extinguish continuing instrument-specific obligations.","Primary evidence and limit":"S017 regulator transition page; S016 §12. Exact present third-party provider category and any 2026 directive need separate determination."},"raw_table_index":10,"coordinator_verification_status":"selected_body_or_arithmetic_supported_currentness_and_application_held","coordinator_review":"Keep function-specific dates:11August licensing-related functions and2September high-value handover. Do not use2September as the date every licensing power transferred.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00","coordinator_pinpoint_annotation":"Keep function-specific dates:11August licensing-related functions and2September high-value handover. Do not use2September as the date every licensing power transferred."},{"claim_id":"C_ZA-C031","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C031","Exact bounded proposition, conditions, act and consequence":"NCA §4 has territorial rules relevant to a credit agreement involving a foreign creditor or South African effect; it does not alone settle the extraterritorial licensing status of a remotely operating debt adviser. Determine each service, targeted market, location, mandate and fund flow before asserting South African permission or exemption.","Primary evidence and limit":"S001 §4(1)–(3); S015 §1; S016 §7. Partial nexus inference; foreign-assets/judgment questions reserved to A098."},"raw_table_index":11,"coordinator_verification_status":"traceability_and_explicit_limits_checked_remaining_primary_verification_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"},{"claim_id":"C_ZA-C032","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C032","Exact bounded proposition, conditions, act and consequence":"National Credit Amendment Act 7 of 2019 §32 provides for commencement by presidential proclamation; enactment/publication in August 2019 is not the commencement event. A qualifying commencement proclamation had not been established in this research as at access on 26 Oct 2026.","Primary evidence and limit":"S012 §§31–32, PDF P40 / GG p.42; S011 legislative metadata. This is unknown operative status, not a claim that no proclamation exists."},"raw_table_index":11,"coordinator_verification_status":"traceability_and_explicit_limits_checked_remaining_primary_verification_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00","coordinator_P02_reconciliation":{"at":"2026-10-27T00:57:43.962914+00:00","review":"[internal evidence reference]","replacement_or_supplement_claim_ids":["C_ZA-P02-C001","C_ZA-P02-C002","C_ZA-P02-C003","C_ZA-P02-C024"],"disposition":"Correct controlling source provenance: withdrawn P01S012 retained ashistory; finalP02S001 replaces it for enacted text. Unknown-operative-status hold remains.","original_researcher_record_preserved":true,"current_country_acceptance":false}},{"claim_id":"C_ZA-C033","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C033","Exact bounded proposition, conditions, act and consequence":"The specific August 2025 draft NCA regulations concerning credit-information reporting, including the contested education/SME issue, were withdrawn according to dtic’s September statement and November parliamentary briefing. They cannot supply a binding 2026 permission requirement.","Primary evidence and limit":"S021 PDF P1, P4–7; S036 12 Sep 2025 statement. Scope limited to that draft; no general claim about other NCA rules."},"raw_table_index":11,"coordinator_verification_status":"traceability_and_explicit_limits_checked_remaining_primary_verification_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00","coordinator_P02_reconciliation":{"at":"2026-10-27T00:57:43.962914+00:00","review":"[internal evidence reference]","replacement_or_supplement_claim_ids":["C_ZA-P02-C019","C_ZA-P02-C020","C_ZA-P02-C021","C_ZA-P02-C024"],"disposition":"Keep actual bounded original claim and application/currentness limits.","original_researcher_record_preserved":true,"current_country_acceptance":false}},{"claim_id":"C_ZA-C034","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C034","Exact bounded proposition, conditions, act and consequence":"The consequences for an unlawful credit agreement under amended NCA §89, including amended judicial treatment, are a different question from a counsellor/negotiator’s registration breach. Nothing in the read rules makes provider misconduct automatically cancel the customer’s underlying debt, release security or erase a judgment.","Primary evidence and limit":"S001 §89; S002 amendment to §89; S035 P44–45. Actual relief, standing, judicial findings and contractual effects not adjudicated."},"raw_table_index":11,"coordinator_verification_status":"traceability_and_explicit_limits_checked_remaining_primary_verification_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"},{"claim_id":"C_ZA-C035","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C035","Exact bounded proposition, conditions, act and consequence":"Legal practice requires the relevant LPC admission/enrolment and valid entity/practice capacity under LPA §§24, 30, 34, with distinct conditions for legal-practice structures and qualifying clinics. A person’s professional title does not itself establish the actual engagement’s mandate.","Primary evidence and limit":"S009 §§24, 30, 34, PDF P11–15; S027 public entry point. No professional searched."},"raw_table_index":11,"coordinator_verification_status":"traceability_and_explicit_limits_checked_remaining_primary_verification_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"},{"claim_id":"C_ZA-C036","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C036","Exact bounded proposition, conditions, act and consequence":"Conditional negative finding: no categorical exemption from actual NCA §44 debt-counselling functions was established merely for a charity, consumer organisation, nonprofit, free service, accountant, attorney or other qualified person. The activity, statutory text and any specific exception must be tested independently.","Primary evidence and limit":"S001 §44; S002 §163(1C); S007 §1; S009 §§33–34. Not a claim that no activity-specific exemption anywhere exists."},"raw_table_index":11,"coordinator_verification_status":"traceability_and_explicit_limits_checked_remaining_primary_verification_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"},{"claim_id":"C_ZA-C037","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C037","Exact bounded proposition, conditions, act and consequence":"A creditor recovering its own claim is not automatically the same Debt Collectors Act actor as a person collecting an amount owed to another for reward; however the amended §1 expressly brings certain overdue debt purchasers into scope. A servicer’s mandate and assignment terms can move the result.","Primary evidence and limit":"S007 §1; S001 §1 “credit provider” definitions. Actual purchase, factoring and remuneration facts required."},"raw_table_index":11,"coordinator_verification_status":"selected_body_or_arithmetic_supported_currentness_and_application_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"},{"claim_id":"C_ZA-C038","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C038","Exact bounded proposition, conditions, act and consequence":"Statutory debt review proceeds through NCA §86 application/assessment and the paths to a competent Tribunal or court under §§86–87. A private creditor workout may exist without those statutory acts, but cannot claim their procedural status or outcome.","Primary evidence and limit":"S001 §§86–87; S002 amended §86; S013 P6–8. Full eligibility, forms, effects and timelines deferred."},"raw_table_index":11,"coordinator_verification_status":"traceability_and_explicit_limits_checked_remaining_primary_verification_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00","coordinator_P02_reconciliation":{"at":"2026-10-27T00:57:43.962914+00:00","review":"[internal evidence reference]","replacement_or_supplement_claim_ids":["C_ZA-P02-C022","C_ZA-P02-C024","C_ZA-P02-C025"],"disposition":"Original exact claim expressly includes competentTribunal orcourt; preserve it. P02paragraph namingMagistratesCourt is not an exclusive-current-route conclusion; fullprocedure held.","original_researcher_record_preserved":true,"current_country_acceptance":false}},{"claim_id":"C_ZA-C039","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C039","Exact bounded proposition, conditions, act and consequence":"NCR’s public materials distinguish registered, cancelled and lapsed category records. A bare historic registration number does not establish present status, scope, employment, mandate, company authorisation, fee legality or creditor assent.","Primary evidence and limit":"S010 public register entry point; S001 §§44–52. No live individual/entity search performed."},"raw_table_index":11,"coordinator_verification_status":"traceability_and_explicit_limits_checked_remaining_primary_verification_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"},{"claim_id":"C_ZA-C040","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C040","Exact bounded proposition, conditions, act and consequence":"Under the 2016 notice only, R550 + R500 = R1,050 for the illustrated application/category components, and R550 + R100,000 = R100,550 for the illustrated PDA components. Under regulation 10A(6), a hypothetical R2,000,000 aggregate amount collected for distribution yields an equivalent R2,000,000 illustrative compensatory value; R5,000,000 capital remains separate.","Primary evidence and limit":"S006 item 2, Tables C–D; S004 reg10A(5)–(6). Arithmetic correct for stated assumptions, not 2026 fees, actual insurance suitability, consumer cost or debt reduction."},"raw_table_index":11,"coordinator_verification_status":"selected_body_or_arithmetic_supported_currentness_and_application_held","coordinator_review":"Dated arithmetic verified; TablesC/D arise under item3, separate from item2 application amount. Insurance comparator not premium, policy approval or client money.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00","coordinator_pinpoint_annotation":"Dated arithmetic verified; TablesC/D arise under item3, separate from item2 application amount. Insurance comparator not premium, policy approval or client money."},{"claim_id":"C_ZA-C041","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C041","Exact bounded proposition, conditions, act and consequence":"For magistrates’ administration, the court appoints the administrator under §74E, subject to statutory eligibility/security criteria. Custody and accounting are not established simply by accepting client funds; §74J has distinct administrator duties.","Primary evidence and limit":"S018 §§74E, 74J, PDF P35, P37. Whether a particular officer qualifies requires order and role documents."},"raw_table_index":11,"coordinator_verification_status":"traceability_and_explicit_limits_checked_remaining_primary_verification_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"},{"claim_id":"C_ZA-C042","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C042","Exact bounded proposition, conditions, act and consequence":"For company business rescue, CIPC licensing/category and actual company/court appointment are separate predicates. The professional status of one consultant does not automatically vest authority in their entire company or every employee.","Primary evidence and limit":"S019 regs126–127; S030; S028. Current verbatim Companies Act §138 and specific appointment not verified."},"raw_table_index":11,"coordinator_verification_status":"traceability_and_explicit_limits_checked_remaining_primary_verification_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"},{"claim_id":"C_ZA-C043","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C043","Exact bounded proposition, conditions, act and consequence":"The 2006 official threshold notice contains R1,000,000 for the specified juristic-person §4 threshold and R250,000 for the large-agreement classification, alongside R15,000 small/other categories. These figures are historically sourced, not conclusively verified as current on 26 Oct 2026.","Primary evidence and limit":"S023 ¶¶2–3, PDF P0 / GG p.3; S001 §§4, 9. Must check later operative notices before publishing a current eligibility cutoff."},"raw_table_index":11,"coordinator_verification_status":"traceability_and_explicit_limits_checked_remaining_primary_verification_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"},{"claim_id":"C_ZA-C044","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C044","Exact bounded proposition, conditions, act and consequence":"Joint signatures, a director’s signature, personal suretyship, borrower identity and guarantee status are distinct classification facts under NCA definitions/§§4 and 8. None alone establishes whose credit agreement is subject to §86 review.","Primary evidence and limit":"S001 §§1, 4, 8, 86. Contract-specific inference; no assumption that joint borrowing and suretyship are legally identical."},"raw_table_index":11,"coordinator_verification_status":"traceability_and_explicit_limits_checked_remaining_primary_verification_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"},{"claim_id":"C_ZA-C045","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C045","Exact bounded proposition, conditions, act and consequence":"The enacted 2019 debt-intervention amendments must not be advertised as an operating statutory benefit unless their proclamation, commencement and presently operative procedures are independently demonstrated.","Primary evidence and limit":"S012 §32; S011 legislative metadata. Publication hold, not determination of permanent noncommencement."},"raw_table_index":11,"coordinator_verification_status":"traceability_and_explicit_limits_checked_remaining_primary_verification_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00","coordinator_P02_reconciliation":{"at":"2026-10-27T00:57:43.962914+00:00","review":"[internal evidence reference]","replacement_or_supplement_claim_ids":["C_ZA-P02-C002","C_ZA-P02-C003","C_ZA-P02-C009","C_ZA-P02-C010","C_ZA-P02-C011","C_ZA-P02-C012","C_ZA-P02-C013","C_ZA-P02-C014","C_ZA-P02-C017","C_ZA-P02-C023","C_ZA-P02-C024"],"disposition":"Correct controlling source provenance: withdrawn P01S012 retained ashistory; finalP02S001 replaces it for enacted text. Unknown-operative-status hold remains.","original_researcher_record_preserved":true,"current_country_acceptance":false}},{"claim_id":"C_ZA-C046","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C046","Exact bounded proposition, conditions, act and consequence":"NCA §86(5) addresses good-faith participation within statutory debt review; it must not be transformed into a promise that an ordinary private negotiator can compel a creditor to reduce principal or accept a particular workout.","Primary evidence and limit":"S001 §86(5); S002 §86 amendments. No actual creditor response or settlement agreement reviewed."},"raw_table_index":11,"coordinator_verification_status":"traceability_and_explicit_limits_checked_remaining_primary_verification_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"},{"claim_id":"C_ZA-C047","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C047","Exact bounded proposition, conditions, act and consequence":"An FSCA-authorised financial-services provider and any legally relevant representative have a permission framework only to the extent the actual FAIS product and activity engage it; FSP/representative status is not a universal substitute for NCR, collector or court appointment.","Primary evidence and limit":"S015 §1, §7 (partial); S025 FSCA route; S034 amendment metadata. FAIS current full amended body and category detail unresolved."},"raw_table_index":11,"coordinator_verification_status":"traceability_and_explicit_limits_checked_remaining_primary_verification_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"},{"claim_id":"C_ZA-C048","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C048","Exact bounded proposition, conditions, act and consequence":"NCA §44(3), §47 and regulation 10 impose an education/competence inquiry for individual debt-counsellor registration. NCR’s 2024/25 report identifies an approved course and describes its then-current short course as 10 days; a possible new occupational qualification was still under development then.","Primary evidence and limit":"S001 §§44(3), 47; S024 P0; S035 P24. Historical course description is not a certified October 2026 qualification rule."},"raw_table_index":11,"coordinator_verification_status":"traceability_and_explicit_limits_checked_remaining_primary_verification_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"},{"claim_id":"C_ZA-C049","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C049","Exact bounded proposition, conditions, act and consequence":"An older, undated NCR guide states R100, conflicting with the later official 2016 R500 category. Chronology and instrument type mean the guide cannot displace the gazetted notice; neither establishes the full 2026 amendment chain.","Primary evidence and limit":"S024 P1 versus S006 Table C, PDF P3 / GG p.9. Explicit source conflict; live fee remains unverified."},"raw_table_index":11,"coordinator_verification_status":"traceability_and_explicit_limits_checked_remaining_primary_verification_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"},{"claim_id":"C_ZA-C050","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C050","Exact bounded proposition, conditions, act and consequence":"Debt Collectors Act §26 provides for a ministerial exemption mechanism with its statutory conditions; it does not create an automatic exemption simply because the actor is nonprofit, philanthropic, professionally qualified or charges the debtor nothing.","Primary evidence and limit":"S007 §26, PDF P6. Any specific valid exemption instrument and its beneficiary were not investigated."},"raw_table_index":11,"coordinator_verification_status":"selected_body_or_arithmetic_supported_currentness_and_application_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"},{"claim_id":"C_ZA-C051","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C051","Exact bounded proposition, conditions, act and consequence":"PDA regulation 10A(5)–(9) has its own bank-guaranteed-cheque capital evidence, indemnity, independent-business and payment-account duties, including collection into a bank trust account and distribution/reporting requirements. These duties attach to the regulated PDA, not every business describing itself as a trustee.","Primary evidence and limit":"S004 reg10A(5)–(9), PDF P5–8 / GG pp.10–13. Client-money compliance, regulatory conditions and payment permissions deferred."},"raw_table_index":11,"coordinator_verification_status":"traceability_and_explicit_limits_checked_remaining_primary_verification_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"},{"claim_id":"C_ZA-C052","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C052","Exact bounded proposition, conditions, act and consequence":"NCA §50 addresses effect of NCR registration across the Republic subject to applicable provincial legislation. This is not proof that the laws of all nine provinces, courts, municipalities or specialised sectors have been examined.","Primary evidence and limit":"S001 §50. Each province has an unresolved geographic research row below."},"raw_table_index":11,"coordinator_verification_status":"selected_body_or_arithmetic_supported_currentness_and_application_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"},{"claim_id":"C_ZA-C053","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C053","Exact bounded proposition, conditions, act and consequence":"NPS Act §12 supplies statutory authority for applicable payment-system directives; an actor must first fall within the direction’s defined scope, and any adverse consequence requires its actual operative predicate.","Primary evidence and limit":"S016 §12, PDF P14; S022 Directive 1/2007 P1–3. No blanket claim of a criminal offence for every unregistered “payment administrator”; current 2026 instruments remain to be checked."},"raw_table_index":11,"coordinator_verification_status":"traceability_and_explicit_limits_checked_remaining_primary_verification_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"},{"claim_id":"C_ZA-C054","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C054","Exact bounded proposition, conditions, act and consequence":"A registered individual’s use of an employee or assistant does not let that employee perform every statutory §86 function under the individual’s number. NCA §163(1C)’s administrative task allocation and the actual performed functions decide the boundary.","Primary evidence and limit":"S002 §163(1C), PDF P14–15; S001 §44. Individual staffing agreements and task logs unexamined."},"raw_table_index":11,"coordinator_verification_status":"selected_body_or_arithmetic_supported_currentness_and_application_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"},{"claim_id":"C_ZA-C055","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C055","Exact bounded proposition, conditions, act and consequence":"Pure referrals, educational software and calculation tools are conditionally distinct from personalised statutory counselling, collecting on a creditor’s mandate and controlling consumer payments. If implementation or compensation changes the function, reclassify it.","Primary evidence and limit":"S001 §§44, 86; S007 §1; S015 §1; S016 §7. Activity-based inference; no safe harbour for all lead generators/software suppliers established."},"raw_table_index":11,"coordinator_verification_status":"traceability_and_explicit_limits_checked_remaining_primary_verification_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"},{"claim_id":"C_ZA-C056","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C056","Exact bounded proposition, conditions, act and consequence":"Public NCR, collector, LPC and CIPC registers are read-only category/status checks, not evidence of a particular service contract, debt-owner authority, consumer consent, fund safeguarding, creditor settlement or legal outcome.","Primary evidence and limit":"S010, S026–S028 official interfaces; S001 §44; S007 §8; S009 §30. No named searches; results must be time-stamped if later obtained."},"raw_table_index":11,"coordinator_verification_status":"traceability_and_explicit_limits_checked_remaining_primary_verification_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"},{"claim_id":"C_ZA-C057","area_numbers":[97,98],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim":"C057","Exact bounded proposition, conditions, act and consequence":"Ordinary CIPC entity incorporation does not automatically grant an individual’s NCR debt-counsellor registration, a juristic PDA registration, an FSCA permission or a business-rescue practitioner appointment. Each follows its own statutory actor/category.","Primary evidence and limit":"S001 §44; S004 reg10A; S015 §1 and conditional §7; S019 regs126–127; S030. Company-specific documents absent; current FAIS and rescue amendment checks pending."},"raw_table_index":11,"coordinator_verification_status":"traceability_and_explicit_limits_checked_remaining_primary_verification_held","coordinator_review":"Source-row subject and reported pinpoint mapping reconciled; only source-checks selected bodies received a fresh read. Currentness, precise roles, private instruments and unexamined legal effects remain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00"}],"sources":[{"source_id":"C_ZA-S001","urls":["https://www.justice.gov.za/mc/vnbp/act2005-034.pdf"],"researcher_record":{"ID and issuing source — full direct URL":"S001 — Parliament, National Credit Act 34 of 2005, Justice-hosted enacted text. https://www.justice.gov.za/mc/vnbp/act2005-034.pdf","Actual pinpoint and page identification":"Definitions §1, application §§4–9, NCR §14, debt counsellors §§44–52, debt-review §§85–89. Relevant PDF P8–21, P23, P36–40, P59–62; Gazette printed-page correspondence not fully verified.","Version, status, scope and reading limit":"Opened 26 Oct 2026. Original enacted Act, not a complete current consolidated text. Applied with S002 and commencement qualifications; the original file alone cannot establish an unamended 2026 rule. Republic/covered credit/registered actors. \njustice.gov.za"},"coordinator_verification_status":"fresh_selected_primary_body_checked_with_limits","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_check_scope":"Original enacted NCA selected sections44(1)-(3),14 registration-function passage and50(1)-(2); national registration remains subject to applicable provincial law. No full2026 consolidation or nine-province read.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00","independent_review":false},{"source_id":"C_ZA-S002","urls":["https://www.gov.za/sites/default/files/gcis_document/201409/37665gon389.pdf"],"researcher_record":{"ID and issuing source — full direct URL":"S002 — Parliament, National Credit Amendment Act 19 of 2014, Government Gazette 37665. https://www.gov.za/sites/default/files/gcis_document/201409/37665gon389.pdf","Actual pinpoint and page identification":"Insertion of §44A, amended §86 and insertion of §163(1C), with changes to §89. Relevant PDF P5–6, P11–12, P14–15; the corresponding printed Gazette numeration was not independently reconciled for each passage.","Version, status, scope and reading limit":"Opened 26 Oct 2026. Enacted amending text, with major provisions commencing in March 2015; this research did not establish a complete provision-by-provision commencement table. Read only cited amendments. \ngov.za"},"coordinator_verification_status":"fresh_selected_primary_body_checked_with_limits","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_check_scope":"2014 amendment selected insertion44A and163(1C) text. Amendment sequence42/44A/45 read; C001 vague amendments-to44 reference clarified. Complete commencement/later amendment chain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00","independent_review":false},{"source_id":"C_ZA-S003","urls":["https://www.ncr.org.za/documents/Media%20release%20-%20Debt%20counselling%20Campaign(August)-Final.pdf"],"researcher_record":{"ID and issuing source — full direct URL":"S003 — National Credit Regulator (NCR), August 2022 debt-counselling media release. https://www.ncr.org.za/documents/Media%20release%20-%20Debt%20counselling%20Campaign(August)-Final.pdf","Actual pinpoint and page identification":"Advice on registered individual counsellors, debt review and payments: PDF P0–2; printed pagination not separately established.","Version, status, scope and reading limit":"Opened 26 Oct 2026. Official regulator explanation, not an enacted exemption or independent source of criminal liability. It does not establish a 2026 fee schedule. \nncr.org.za"},"coordinator_verification_status":"register_identity_traceability_and_reported_access_only","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_check_scope":"Original row, URL, issuing subject, dated/currentness and reported reading limits reconciled; source body not freshly recertified by coordinator.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00","independent_review":false},{"source_id":"C_ZA-S004","urls":["https://www.gov.za/sites/default/files/gcis_document/201503/38557rg10382gon202.pdf"],"researcher_record":{"ID and issuing source — full direct URL":"S004 — Minister, National Credit Regulations amendment, Government Notice R202, GG 38557, 13 March 2015. https://www.gov.za/sites/default/files/gcis_document/201503/38557rg10382gon202.pdf","Actual pinpoint and page identification":"Regulation 10A(1)–(9): PDF P3–8, printed GG pp.8–13; amended regulation 11: PDF P11, printed GG p.16. Critical specific parts: 10A(3)(b)–(c), (5), (6), (7), (9)(f)–(g).","Version, status, scope and reading limit":"Opened and rechecked 26 Oct 2026. Final gazetted amendment governing NCR PDA registration and separation; further later amendments not exhaustively excluded. Reg10A(7) additionally requires no distribution for consumers of the applicant’s own debt-counselling business. Regulation 11 prohibits counsellors themselves from collecting/distributing consumer monies. \ngov.za\ngov.za\ngov.za"},"coordinator_verification_status":"fresh_selected_primary_body_checked_with_limits","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_check_scope":"2015 reg10A(3)-(7) organisational/capital/insurance/independence body and substituted reg11 prohibition read; full funds safeguards and later operative changes held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00","independent_review":false},{"source_id":"C_ZA-S005","urls":["https://ncr.org.za/documents/pages/PDA/Requirements%20for%20registration%20as%20a%20payment%20distribution%20agent.pdf"],"researcher_record":{"ID and issuing source — full direct URL":"S005 — NCR, Requirements for Registration as a Payment Distribution Agent. https://ncr.org.za/documents/pages/PDA/Requirements%20for%20registration%20as%20a%20payment%20distribution%20agent.pdf","Actual pinpoint and page identification":"PDF P0–1, issuer document page numbers not independently established; institutional and capability requirements cross-check S004 reg10A.","Version, status, scope and reading limit":"Opened 26 Oct 2026. Undated administrative guide; useful confirmation that PDA is an entity category, not a general natural-person debt-counsellor endorsement. S004 controls over a conflicting guide. \nncr.org.za"},"coordinator_verification_status":"register_identity_traceability_and_reported_access_only","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_check_scope":"Original row, URL, issuing subject, dated/currentness and reported reading limits reconciled; source body not freshly recertified by coordinator.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00","independent_review":false},{"source_id":"C_ZA-S006","urls":["https://www.gov.za/sites/default/files/gcis_document/201605/39981gon514.pdf"],"researcher_record":{"ID and issuing source — full direct URL":"S006 — Minister, prescribed application, registration and renewal amounts, Government Notice 514, GG 39981, 11 May 2016. https://www.gov.za/sites/default/files/gcis_document/201605/39981gon514.pdf","Actual pinpoint and page identification":"Amended Schedule 2 item 2: PDF P1 / GG p.7 (R550 application); item 3 Tables C and D: PDF P3 / GG p.9 (R500 debt counsellor; R100,000 PDA); item 4: PDF P4 / GG p.10 (R250 branch).","Version, status, scope and reading limit":"Opened/rechecked 26 Oct 2026. Final 2016 rule; complete subsequent supersession/fee update chain not certified. These are registration charges, not borrower debt-counselling or settlement fees. \ngov.za"},"coordinator_verification_status":"fresh_selected_primary_body_checked_with_limits","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_check_scope":"2016 notice item2 application550, item3 TablesC/D500/100000, item4 branch qualification and item5 renewal-date body checked as dated text. PDF pixels unavailable; extracted table text only. Full2026 fee chain held.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00","independent_review":false},{"source_id":"C_ZA-S010","urls":["https://ncr.org.za/register/index.html"],"researcher_record":{"ID and issuing source — full direct URL":"S010 — NCR, Public Register navigation. https://ncr.org.za/register/index.html","Actual pinpoint and page identification":"HTML, registered/cancelled/lapsed debt-counsellor and PDA category paths; PDF index not applicable; opened page navigation rather than person/entity results.","Version, status, scope and reading limit":"Opened 26 Oct 2026. Official public lookup entry point; no named lookup performed and no particular registration established. \nncr.org.za"},"coordinator_verification_status":"register_identity_traceability_and_reported_access_only","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_check_scope":"Original row, URL, issuing subject, dated/currentness and reported reading limits reconciled; source body not freshly recertified by coordinator.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00","independent_review":false},{"source_id":"C_ZA-S011","urls":["https://www.gov.za/documents/national-credit-act"],"researcher_record":{"ID and issuing source — full direct URL":"S011 — South African Government, National Credit Act legislative record. https://www.gov.za/documents/national-credit-act","Actual pinpoint and page identification":"HTML, Act title and enactment/commencement metadata; PDF index not applicable.","Version, status, scope and reading limit":"Opened 26 Oct 2026. Official discovery and legislative-context page, not a substitute for section text and amendment commencement. \nSouth African Government"},"coordinator_verification_status":"register_identity_traceability_and_reported_access_only","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_check_scope":"Original row, URL, issuing subject, dated/currentness and reported reading limits reconciled; source body not freshly recertified by coordinator.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00","independent_review":false},{"source_id":"C_ZA-S012","urls":["https://www.gov.za/sites/default/files/gcis_document/201908/42649gon1081.pdf"],"researcher_record":{"ID and issuing source — full direct URL":"S012 — Parliament, National Credit Amendment Act 7 of 2019, GG 42649 alternative official Gazette copy. https://www.gov.za/sites/default/files/gcis_document/201908/42649gon1081.pdf","Actual pinpoint and page identification":"New debt-intervention provisions including §86A: PDF P14–16; §31 transition and §32 commencement: PDF P40 / GG p.42.","Version, status, scope and reading limit":"Opened/rechecked 26 Oct 2026. Enacted 2019 amending Act whose §32 requires presidential proclamation. No operative 2026 proclamation was established here. Therefore its proposed inserted debt-intervention pathway is not represented as in force. Government’s separate Act listing was also consulted. \ngov.za\ngov.za"},"coordinator_verification_status":"register_identity_traceability_and_reported_access_only","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_check_scope":"Original row, URL, issuing subject, dated/currentness and reported reading limits reconciled; source body not freshly recertified by coordinator.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00","independent_review":false,"coordinator_P02_source_correction":{"at":"2026-10-27T00:57:43.962914+00:00","status":"withdrawn_historical_copy_not_controlling_final_enactment","replacement_source":"C_ZA-P02-S001","replacement_url":"https://www.gov.za/sites/default/files/gcis_document/201908/42653gon-1086act7of-2019natcreditamendact.pdf","authority":"FinalGazette42653PDFP1withdraws42649","review":"[internal evidence reference]","raw_original_preserved":true}},{"source_id":"C_ZA-S013","urls":["https://www.thedtic.gov.za/wp-content/uploads/Debt-Review.pdf"],"researcher_record":{"ID and issuing source — full direct URL":"S013 — Department of Trade, Industry and Competition (dtic), Debt Review presentation. https://www.thedtic.gov.za/wp-content/uploads/Debt-Review.pdf","Actual pinpoint and page identification":"Statutory-role process discussion: PDF P6–8; slides have their own visible sequence, not Gazette pages.","Version, status, scope and reading limit":"Opened 26 Oct 2026. Official educational presentation distinguishing registered natural-person debt counsellor from juristic PDA; describes practice but does not independently enact qualifications, fees or court outcomes. \nthedtic.gov.za"},"coordinator_verification_status":"register_identity_traceability_and_reported_access_only","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_check_scope":"Original row, URL, issuing subject, dated/currentness and reported reading limits reconciled; source body not freshly recertified by coordinator.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00","independent_review":false},{"source_id":"C_ZA-S014","urls":["https://www.gov.za/sites/default/files/gcis_document/201409/28864.pdf"],"researcher_record":{"ID and issuing source — full direct URL":"S014 — Minister, original National Credit Regulations, Government Notice R489, GG 28864 (2006). https://www.gov.za/sites/default/files/gcis_document/201409/28864.pdf","Actual pinpoint and page identification":"Regulation 1 definition of debt counselling, PDF P7 / GG approximately p.10; full operative regulation 10 text was not successfully re-opened in this pass.","Version, status, scope and reading limit":"Partially opened 26 Oct 2026. Original regulation; must be layered with 2015 amendments and later notices. Later attempts at the full source returned internal errors, so its qualification specifics remain partly unresolved. \ngov.za"},"coordinator_verification_status":"register_identity_traceability_and_reported_access_only","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_check_scope":"Original row, URL, issuing subject, dated/currentness and reported reading limits reconciled; source body not freshly recertified by coordinator.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00","independent_review":false},{"source_id":"C_ZA-S023","urls":["https://www.gov.za/sites/default/files/gcis_document/201409/28893.pdf"],"researcher_record":{"ID and issuing source — full direct URL":"S023 — Minister, credit-agreement threshold notice, Notice 713, GG 28893 (2006). https://www.gov.za/sites/default/files/gcis_document/201409/28893.pdf","Actual pinpoint and page identification":"Notice paragraphs 2–3: PDF P0 / printed GG p.3; R1 million juristic-person threshold and R15,000/R250,000 agreement-class thresholds.","Version, status, scope and reading limit":"Opened 26 Oct 2026. Official 2006 figures, not demonstrated to be the last legally operative amounts in Oct 2026; the relevant NCA classification tests remain separate. \ngov.za"},"coordinator_verification_status":"register_identity_traceability_and_reported_access_only","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_check_scope":"Original row, URL, issuing subject, dated/currentness and reported reading limits reconciled; source body not freshly recertified by coordinator.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00","independent_review":false},{"source_id":"C_ZA-S024","urls":["https://ncr.org.za/documents/pages/compliance&reports_cp/Requirements%20for%20registration%20as%20a%20debt%20counsellor.pdf"],"researcher_record":{"ID and issuing source — full direct URL":"S024 — NCR, Requirements for Registration as a Debt Counsellor. https://ncr.org.za/documents/pages/compliance&reports_cp/Requirements%20for%20registration%20as%20a%20debt%20counsellor.pdf","Actual pinpoint and page identification":"PDF P0–1; course, education, experience and an older “R100” amount. No dependable date in the document.","Version, status, scope and reading limit":"Opened 26 Oct 2026. Undated/outdated guide: its R100 is inconsistent with S006’s subsequent R500. It is not evidence that R100 is a current payable registration charge. \nncr.org.za"},"coordinator_verification_status":"register_identity_traceability_and_reported_access_only","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_check_scope":"Original row, URL, issuing subject, dated/currentness and reported reading limits reconciled; source body not freshly recertified by coordinator.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00","independent_review":false},{"source_id":"C_ZA-S029","urls":["https://www.thedtic.gov.za/wp-content/uploads/National_Credit_Act34of2005.pdf"],"researcher_record":{"ID and issuing source — full direct URL":"S029 — dtic, dated consolidation of National Credit Act. https://www.thedtic.gov.za/wp-content/uploads/National_Credit_Act34of2005.pdf","Actual pinpoint and page identification":"Consolidated §44/§86 framework and amendment markers: relevant PDF P35–40 and P75–79; internal printed-page alignment varies with layout.","Version, status, scope and reading limit":"Opened 26 Oct 2026. Dated compilation useful for tracing older amendments, not a 2026-certified consolidation. Its notes were not used as proof that no later proclamation exists. \nthedtic.gov.za"},"coordinator_verification_status":"register_identity_traceability_and_reported_access_only","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_check_scope":"Original row, URL, issuing subject, dated/currentness and reported reading limits reconciled; source body not freshly recertified by coordinator.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00","independent_review":false},{"source_id":"C_ZA-S035","urls":["https://www.thedtic.gov.za/wp-content/uploads/NCR-Annual-Report-2024_2025.pdf"],"researcher_record":{"ID and issuing source — full direct URL":"S035 — NCR Annual Report 2024/25, published through dtic. https://www.thedtic.gov.za/wp-content/uploads/NCR-Annual-Report-2024_2025.pdf","Actual pinpoint and page identification":"Debt-counselling qualification discussion PDF P24; NCR compliance, PDA supervision and enforcement PDF P44–45, report printed pp.44–45 in Part B.","Version, status, scope and reading limit":"Opened 26 Oct 2026. Official regulator retrospective evidence: training expectations, compliance monitoring and that actual enforcement requires an adjudicative process. It reports two category-related Tribunal outcomes without this research opening either underlying decision. Historical programme description, not proof of all 2026 criteria. \nthedtic.gov.za"},"coordinator_verification_status":"register_identity_traceability_and_reported_access_only","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_check_scope":"Original row, URL, issuing subject, dated/currentness and reported reading limits reconciled; source body not freshly recertified by coordinator.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00","independent_review":false},{"source_id":"C_ZA-S007","urls":["https://www.justice.gov.za/legislation/acts/1998-114.pdf"],"researcher_record":{"ID and issuing source — full direct URL":"S007 — Parliament, Debt Collectors Act 114 of 1998, Justice-hosted annotated text. https://www.justice.gov.za/legislation/acts/1998-114.pdf","Actual pinpoint and page identification":"§1 definitions and exclusions PDF P0; registration §§8–10 PDF P2; register §12 PDF P3; offences/exemptions §§25–26 PDF P6. Printed internal statute page numbers broadly 1–7, not official GG pagination.","Version, status, scope and reading limit":"Opened 26 Oct 2026. Justice-hosted amended statute; amendment dates to be verified separately for a definitive consolidation. Covers collection for another, specified purchasers and actual statutory exceptions; not automatic authorisation for debtor-side debt review. \njustice.gov.za"},"coordinator_verification_status":"fresh_selected_primary_body_checked_with_limits","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_check_scope":"Justice-hosted annotated collector Act selected1,8-10,25,26. Compilation carries2025 download annotation and listed amendments; not exhaustive2026 certification. Definitions/exceptions and actual roles must be applied separately.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00","independent_review":false},{"source_id":"C_ZA-S008","urls":["https://www.justice.gov.za/legislation/notices/2026/20260306-gg54273rg11951gon7207-DebtCollectors-Regulations.pdf"],"researcher_record":{"ID and issuing source — full direct URL":"S008 — Minister of Justice, 2026 amendments to Debt Collectors Regulations, Government Notice 7207, GG 54273, 6 March 2026. https://www.justice.gov.za/legislation/notices/2026/20260306-gg54273rg11951gon7207-DebtCollectors-Regulations.pdf","Actual pinpoint and page identification":"Regulation 11 substituted tariff: PDF P0–1 / printed GG pp.52–53. Distinct item caps include the stated R1,225 and R610 qualifications.","Version, status, scope and reading limit":"Opened 26 Oct 2026. Final 2026 Gazette notice. Creditor-side collection-cost tariff, not a debtor-paid negotiation fee schedule. Its application predicates and per-item distinctions must accompany any consumer-facing treatment. \njustice.gov.za"},"coordinator_verification_status":"fresh_selected_primary_body_checked_with_limits","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_check_scope":"6March2026 notice item2 replaces regulation11 amount1023 with1225; item3 replaces AnnexB. Annex note items1-7 lesser capital/1225; item9 tenpercent instalment capped610 checked. Not debtor-adviser tariff or general total-fee cap.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00","independent_review":false},{"source_id":"C_ZA-S009","urls":["https://www.justice.gov.za/legislation/acts/2014-028.pdf"],"researcher_record":{"ID and issuing source — full direct URL":"S009 — Parliament, Legal Practice Act 28 of 2014, Justice-hosted amended text. https://www.justice.gov.za/legislation/acts/2014-028.pdf","Actual pinpoint and page identification":"Admission and enrolment §§24 and 30, restrictions and practices §§33–34: PDF P11–15; internal compilation page numbering used, rather than Gazette p.","Version, status, scope and reading limit":"Opened 26 Oct 2026. Enacted/annotated text with provision-level commencement caveats. Does not establish that all ordinary debt explanations or all voluntary negotiations are reserved legal practice. Nor does attorney status confer NCR registration. \njustice.gov.za"},"coordinator_verification_status":"register_identity_traceability_and_reported_access_only","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_check_scope":"Original row, URL, issuing subject, dated/currentness and reported reading limits reconciled; source body not freshly recertified by coordinator.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00","independent_review":false},{"source_id":"C_ZA-S025","urls":["https://www.fsca.co.za/New-Financial-Service-Provider/"],"researcher_record":{"ID and issuing source — full direct URL":"S025 — Financial Sector Conduct Authority (FSCA), New Financial Service Provider guidance. https://www.fsca.co.za/New-Financial-Service-Provider/","Actual pinpoint and page identification":"HTML provider and representative regulatory route; PDF index not applicable.","Version, status, scope and reading limit":"Opened 26 Oct 2026. Regulator operational guidance; only relevant when actual service is a defined financial service involving an applicable product. Does not establish that ordinary debt settlement always needs an FSP licence. \nfsca.co.za"},"coordinator_verification_status":"register_identity_traceability_and_reported_access_only","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_check_scope":"Original row, URL, issuing subject, dated/currentness and reported reading limits reconciled; source body not freshly recertified by coordinator.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00","independent_review":false},{"source_id":"C_ZA-S026","urls":["https://www.cfdc.org.za/active-register/"],"researcher_record":{"ID and issuing source — full direct URL":"S026 — Council for Debt Collectors, active register entrance. https://www.cfdc.org.za/active-register/","Actual pinpoint and page identification":"HTML public register interface; PDF index not applicable.","Version, status, scope and reading limit":"Opened 26 Oct 2026. Official capacity-check route; no named collector was queried. A listing alone does not establish which particular engagement is authorised. \nDebt Collectors Register"},"coordinator_verification_status":"register_identity_traceability_and_reported_access_only","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_check_scope":"Original row, URL, issuing subject, dated/currentness and reported reading limits reconciled; source body not freshly recertified by coordinator.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00","independent_review":false},{"source_id":"C_ZA-S027","urls":["https://lpc.org.za/members-of-the-public/search-practitioners/"],"researcher_record":{"ID and issuing source — full direct URL":"S027 — Legal Practice Council, Search Practitioners interface. https://lpc.org.za/members-of-the-public/search-practitioners/","Actual pinpoint and page identification":"HTML public search instructions; PDF index not applicable.","Version, status, scope and reading limit":"Opened 26 Oct 2026. Official professional-capacity route; no named practitioner lookup conducted. Admission and a particular client mandate remain distinct. \nLegal Practice Council"},"coordinator_verification_status":"register_identity_traceability_and_reported_access_only","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_check_scope":"Original row, URL, issuing subject, dated/currentness and reported reading limits reconciled; source body not freshly recertified by coordinator.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00","independent_review":false},{"source_id":"C_ZA-S015","urls":["https://www.gov.za/sites/default/files/gcis_document/201409/a37-020.pdf"],"researcher_record":{"ID and issuing source — full direct URL":"S015 — Parliament, Financial Advisory and Intermediary Services Act 37 of 2002, government-hosted original. https://www.gov.za/sites/default/files/gcis_document/201409/a37-020.pdf","Actual pinpoint and page identification":"§1 defined “financial product,” “advice” and “intermediary service”: PDF P3–4; §7 licensing identified, but its currently amended complete body and exemptions were not fully read. Printed enactment pagination not separately recorded.","Version, status, scope and reading limit":"Partially opened 26 Oct 2026. Original Act, not reliable alone as a 2026 consolidation. Consequently FAIS is a conditional activity/product screen, not a conclusion that debt negotiators all require FSCA registration. \ngov.za"},"coordinator_verification_status":"register_identity_traceability_and_reported_access_only","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_check_scope":"Original row, URL, issuing subject, dated/currentness and reported reading limits reconciled; source body not freshly recertified by coordinator.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00","independent_review":false},{"source_id":"C_ZA-S016","urls":["https://www.resbank.co.za/content/dam/sarb/what-we-do/payments-and-settlements/regulation-oversight/NPS%20Act.pdf"],"researcher_record":{"ID and issuing source — full direct URL":"S016 — Parliament/South African Reserve Bank (SARB), National Payment System Act 78 of 1998, SARB-hosted amended compilation. https://www.resbank.co.za/content/dam/sarb/what-we-do/payments-and-settlements/regulation-oversight/NPS%20Act.pdf","Actual pinpoint and page identification":"§7, regular acceptance of money/payment instructions for payment to a third party: PDF P9–10; binding directions §12: PDF P14. Printed statute-page numbering not independently mapped.","Version, status, scope and reading limit":"Opened 26 Oct 2026. SARB-hosted text incorporating significant amendments through approximately 2008; not certified fully consolidated through 2026. The amended §7 takes priority over an obsolete original. Do not equate NCA PDA permission with every required payment-system permission. \nresbank.co.za"},"coordinator_verification_status":"register_identity_traceability_and_reported_access_only","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_check_scope":"Original row, URL, issuing subject, dated/currentness and reported reading limits reconciled; source body not freshly recertified by coordinator.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00","independent_review":false},{"source_id":"C_ZA-S017","urls":["https://www.resbank.co.za/en/home/what-we-do/payments-and-settlements/psmb"],"researcher_record":{"ID and issuing source — full direct URL":"S017 — SARB, Payment System Management Body transition page. https://www.resbank.co.za/en/home/what-we-do/payments-and-settlements/psmb","Actual pinpoint and page identification":"HTML sections describing 2026 functional transfer and 2 September 2026 high-value arrangement change; PDF index not applicable.","Version, status, scope and reading limit":"Opened 26 Oct 2026. Current regulator operational announcement; not an all-category licensing instrument. PASA’s earlier PSMB role cannot simply be carried forward unchanged. \nresbank.co.za\nresbank.co.za"},"coordinator_verification_status":"fresh_selected_primary_body_checked_with_limits","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_check_scope":"SARB institutional page distinguishes11August2026 licensing/authorisation/registration function announcement from2September high-value/PayInc handover; some generic timetable language differs. No blanket payment permission or all-directive currentness inferred.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00","independent_review":false},{"source_id":"C_ZA-S018","urls":["https://www.justice.gov.za/legislation/acts/1944-032.pdf"],"researcher_record":{"ID and issuing source — full direct URL":"S018 — Parliament, Magistrates’ Courts Act 32 of 1944, Justice-hosted amended text. https://www.justice.gov.za/legislation/acts/1944-032.pdf","Actual pinpoint and page identification":"Administration order §74: PDF P32; appointment §74E: PDF P35; account/funds-related §74J: PDF P37; §74P: PDF P38. Printed amended-act page numbers not separately verified.","Version, status, scope and reading limit":"Opened 26 Oct 2026. National statute for a distinct court-controlled procedure. Not evidence of a private firm’s appointment or universal consumer access to an order. \njustice.gov.za"},"coordinator_verification_status":"register_identity_traceability_and_reported_access_only","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_check_scope":"Original row, URL, issuing subject, dated/currentness and reported reading limits reconciled; source body not freshly recertified by coordinator.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00","independent_review":false},{"source_id":"C_ZA-S019","urls":["https://www.gov.za/sites/default/files/gcis_document/201409/34239rg9526gon351c.pdf"],"researcher_record":{"ID and issuing source — full direct URL":"S019 — Minister, Companies Regulations 2011, government-hosted Part C. https://www.gov.za/sites/default/files/gcis_document/201409/34239rg9526gon351c.pdf","Actual pinpoint and page identification":"Business-rescue practitioner licensing criteria, regulations 126–127, PDF P20–23; printed Gazette page number not independently reconciled.","Version, status, scope and reading limit":"Opened 26 Oct 2026. Final subordinate rules and qualification categories. The complete currently amended Companies Act §138 was not successfully opened; this source alone cannot decide a particular rescue appointment. \nPart C"},"coordinator_verification_status":"register_identity_traceability_and_reported_access_only","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_check_scope":"Original row, URL, issuing subject, dated/currentness and reported reading limits reconciled; source body not freshly recertified by coordinator.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00","independent_review":false},{"source_id":"C_ZA-S020","urls":["https://www.justice.gov.za/legislation/acts/1936-024.pdf"],"researcher_record":{"ID and issuing source — full direct URL":"S020 — Parliament, Insolvency Act 24 of 1936, Justice-hosted amended text. https://www.justice.gov.za/legislation/acts/1936-024.pdf","Actual pinpoint and page identification":"Debtor’s petition and court acceptance §§3, 6, PDF P3–5; trustee appointment/security/removal §§56–57, 60, PDF P31–34. Printed compilation page mapping not verified.","Version, status, scope and reading limit":"Opened 26 Oct 2026. Distinct court/Master legal capacity; not a voluntary settlement licence. The full estate process, discharge and priorities were not reviewed. \njustice.gov.za"},"coordinator_verification_status":"register_identity_traceability_and_reported_access_only","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_check_scope":"Original row, URL, issuing subject, dated/currentness and reported reading limits reconciled; source body not freshly recertified by coordinator.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00","independent_review":false},{"source_id":"C_ZA-S021","urls":["https://www.thedtic.gov.za/wp-content/uploads/re-Revised-Part-A-Regs.pdf"],"researcher_record":{"ID and issuing source — full direct URL":"S021 — dtic briefing to parliamentary portfolio committee, 12 November 2025. https://www.thedtic.gov.za/wp-content/uploads/re-Revised-Part-A-Regs.pdf","Actual pinpoint and page identification":"Label and description of withdrawn 2025 draft National Credit Regulations, especially PDF P1, P4–7, slide labels approximately 2 and 5–8.","Version, status, scope and reading limit":"Opened and rechecked 26 Oct 2026. Government explanation of withdrawal, not a statute. Crucial limit: relates to the August 2025 draft credit-information/SME amendments, not proof that every possible 2025 NCA rule or all future proposals were withdrawn. \nthedtic.gov.za"},"coordinator_verification_status":"register_identity_traceability_and_reported_access_only","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_check_scope":"Original row, URL, issuing subject, dated/currentness and reported reading limits reconciled; source body not freshly recertified by coordinator.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00","independent_review":false},{"source_id":"C_ZA-S022","urls":["https://www.resbank.co.za/content/dam/sarb/what-we-do/payments-and-settlements/regulation-oversight/D1_2007(ThirdParty).pdf"],"researcher_record":{"ID and issuing source — full direct URL":"S022 — SARB, Directive 1 of 2007 on payments to third persons. https://www.resbank.co.za/content/dam/sarb/what-we-do/payments-and-settlements/regulation-oversight/D1_2007(ThirdParty).pdf","Actual pinpoint and page identification":"Third-party payer/beneficiary-agent directions and associated requirements, PDF P1–3; original directive pagination distinct from PDF index and not independently matched.","Version, status, scope and reading limit":"Opened 26 Oct 2026. SARB-issued directive, not general debtor-payment permission. Its status alongside the 2026 transfer of PSMB functions and subsequent instruments needs an updated NPS rule-by-rule check. \nresbank.co.za"},"coordinator_verification_status":"register_identity_traceability_and_reported_access_only","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_check_scope":"Original row, URL, issuing subject, dated/currentness and reported reading limits reconciled; source body not freshly recertified by coordinator.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00","independent_review":false},{"source_id":"C_ZA-S028","urls":["https://www.cipc.co.za/?page_id=4745"],"researcher_record":{"ID and issuing source — full direct URL":"S028 — Companies and Intellectual Property Commission (CIPC), business-rescue practitioner public information. https://www.cipc.co.za/?page_id=4745","Actual pinpoint and page identification":"HTML practitioner/licensing status listing with 7 October 2026 page update; PDF index not applicable.","Version, status, scope and reading limit":"Opened 26 Oct 2026. Public CIPC category/status information; no named practitioner was queried. A category listing is not itself an appointment to a particular company. \nCIPC"},"coordinator_verification_status":"register_identity_traceability_and_reported_access_only","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_check_scope":"Original row, URL, issuing subject, dated/currentness and reported reading limits reconciled; source body not freshly recertified by coordinator.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00","independent_review":false},{"source_id":"C_ZA-S030","urls":["https://www.cipc.co.za/?page_id=4635"],"researcher_record":{"ID and issuing source — full direct URL":"S030 — CIPC, Business Rescue Practitioner information. https://www.cipc.co.za/?page_id=4635","Actual pinpoint and page identification":"HTML descriptions of licence and appointment route, including its reference to Companies Act §138; PDF index not applicable.","Version, status, scope and reading limit":"Opened 26 Oct 2026. Competent registrar’s guidance. The precise currently amended statutory text and each practitioner category’s full conditions still require operative-act verification. \nCIPC"},"coordinator_verification_status":"register_identity_traceability_and_reported_access_only","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_check_scope":"Original row, URL, issuing subject, dated/currentness and reported reading limits reconciled; source body not freshly recertified by coordinator.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00","independent_review":false},{"source_id":"C_ZA-S033","urls":["https://www.gov.za/sites/default/files/gcis_document/201409/34239rg9526gon351i.pdf"],"researcher_record":{"ID and issuing source — full direct URL":"S033 — Minister, 2011 Companies Regulations forms appendix. https://www.gov.za/sites/default/files/gcis_document/201409/34239rg9526gon351i.pdf","Actual pinpoint and page identification":"Example CoR 126.1 application/licensing template, PDF P7–8; Gazette printed page not independently captured.","Version, status, scope and reading limit":"Opened 26 Oct 2026. An issued 2011 form only. It does not prove an individual licence, a current filing version or any appointment. No form submitted. \nPart I"},"coordinator_verification_status":"register_identity_traceability_and_reported_access_only","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_check_scope":"Original row, URL, issuing subject, dated/currentness and reported reading limits reconciled; source body not freshly recertified by coordinator.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00","independent_review":false},{"source_id":"C_ZA-S031","urls":["https://www.gov.za/sites/default/files/gcis_document/202508/53154rg11867gon6510.pdf"],"researcher_record":{"ID and issuing source — full direct URL":"S031 — Minister, August 2025 draft NCA regulations, GG 53154. https://www.gov.za/sites/default/files/gcis_document/202508/53154rg11867gon6510.pdf","Actual pinpoint and page identification":"Draft text PDF P0–3, but substantive scanned text not reliably extracted or verified; printed Gazette pagination not confirmed.","Version, status, scope and reading limit":"Discovery/partly unread only, accessed 26 Oct 2026. Subsequently withdrawn draft as described more precisely in S021 and S036; never used as operative permission or an enforceable requirement. \ngov.za"},"coordinator_verification_status":"register_identity_traceability_and_reported_access_only","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_check_scope":"Original row, URL, issuing subject, dated/currentness and reported reading limits reconciled; source body not freshly recertified by coordinator.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00","independent_review":false},{"source_id":"C_ZA-S032","urls":["https://www.gov.za/sites/default/files/gcis_document/201409/a78-98.pdf"],"researcher_record":{"ID and issuing source — full direct URL":"S032 — Parliament, original National Payment System Act 78 of 1998. https://www.gov.za/sites/default/files/gcis_document/201409/a78-98.pdf","Actual pinpoint and page identification":"Original §7: PDF P4; printed enactment page not separately checked.","Version, status, scope and reading limit":"Opened 26 Oct 2026 as historical comparison; superseded wording. Do not cite its unamended §7 as the current payment-permission test; use S016 with further-currentness reservation. \ngov.za"},"coordinator_verification_status":"register_identity_traceability_and_reported_access_only","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_check_scope":"Original row, URL, issuing subject, dated/currentness and reported reading limits reconciled; source body not freshly recertified by coordinator.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00","independent_review":false},{"source_id":"C_ZA-S034","urls":["https://www.gov.za/st/documents/financial-advisory-and-intermediary-services-act"],"researcher_record":{"ID and issuing source — full direct URL":"S034 — South African Government, FAIS Act legislative listing. https://www.gov.za/st/documents/financial-advisory-and-intermediary-services-act","Actual pinpoint and page identification":"HTML Act/amendment metadata; PDF index not applicable.","Version, status, scope and reading limit":"Opened 26 Oct 2026. Confirms the need to account for legislation later than S015; metadata only, not a complete operative FAIS exemption/license rule. \nSouth African Government"},"coordinator_verification_status":"register_identity_traceability_and_reported_access_only","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_check_scope":"Original row, URL, issuing subject, dated/currentness and reported reading limits reconciled; source body not freshly recertified by coordinator.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00","independent_review":false},{"source_id":"C_ZA-S036","urls":["https://www.thedtic.gov.za/minister-tau-withdraws-the-national-credit-act-amendment-regulations/"],"researcher_record":{"ID and issuing source — full direct URL":"S036 — dtic, Minister’s withdrawal statement, 12 September 2025. https://www.thedtic.gov.za/minister-tau-withdraws-the-national-credit-act-amendment-regulations/","Actual pinpoint and page identification":"HTML statement, paragraph beginning “The Minister … has withdrawn” and its description of the educational-institution credit-information issue; PDF index not applicable.","Version, status, scope and reading limit":"Opened 26 Oct 2026. Official explanation of a particular draft withdrawal, not an amendment or a general debt-counselling ruling. Read together with S021 rather than extending its subject matter. \nthedtic.gov.za"},"coordinator_verification_status":"register_identity_traceability_and_reported_access_only","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_check_scope":"Original row, URL, issuing subject, dated/currentness and reported reading limits reconciled; source body not freshly recertified by coordinator.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00","independent_review":false},{"source_id":"C_ZA-S037","urls":["https://www.ncr.org.za/documents/Guidelines/Guideline%20February%202026.pdf"],"researcher_record":{"ID and issuing source — full direct URL":"S037 — NCR, Guideline 001/2026 concerning clearance certificates through CBA platform, February 2026. https://www.ncr.org.za/documents/Guidelines/Guideline%20February%202026.pdf","Actual pinpoint and page identification":"Background and guidance purpose PDF P1; platform directions P2; transition P3. Printed guideline pages 1–3.","Version, status, scope and reading limit":"Opened 26 Oct 2026. Demonstrates that NCR procedures and issued guidance can change during 2026. Clearance-certificate filing requirements, timing and credit-reporting outcomes are deferred, not adopted into this authorisation gateway. \nncr.org.za"},"coordinator_verification_status":"register_identity_traceability_and_reported_access_only","id_normalization":"Unprefixed visible ID qualified by this task; original cell unchanged.","coordinator_check_scope":"Original row, URL, issuing subject, dated/currentness and reported reading limits reconciled; source body not freshly recertified by coordinator.","coordinator_review_file":"[internal evidence reference]","coordinator_checked_at":"2026-10-27T00:08:34.702926+00:00","independent_review":false}],"coverage":[{"topic":"A01 General advice/budgeting versus statutory debt counselling. Core activity comparison; Scenarios 1–2.","researcher_record":{"Row":"A01","Material question and finding location":"General advice/budgeting versus statutory debt counselling. Core activity comparison; Scenarios 1–2.","Status and exact claim IDs":"partial — C001, C003, C005, C036","Missing evidence / next focused action":"Test the particular personalised assessment, recommendations, marketing and any other professional rules; do not create a categorical education exemption."},"raw_table_index":12,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"A02 NCR debt-counsellor registration and holding out. Core provider table; Scenario 1.","researcher_record":{"Row":"A02","Material question and finding location":"NCR debt-counsellor registration and holding out. Core provider table; Scenario 1.","Status and exact claim IDs":"answered — C001, C002, C004","Missing evidence / next focused action":"For any later actual actor, verify individual status/date and real task allocation; no lookup authorised here."},"raw_table_index":12,"coordinator_acceptance":"scoped_findings_traceability_checked_not_country_acceptance","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"A03 Voluntary creditor negotiation, remission, repayment arrangements. Core comparison; Scenario 3.","researcher_record":{"Row":"A03","Material question and finding location":"Voluntary creditor negotiation, remission, repayment arrangements. Core comparison; Scenario 3.","Status and exact claim IDs":"partial — C005, C006, C038, C046","Missing evidence / next focused action":"Resolve legal-practice, collection, mandate and funds-flow triggers; no unconditional settlement right found."},"raw_table_index":12,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"A04 Payment collection/distribution boundary. Actor/authority findings; Scenarios 1 and 6.","researcher_record":{"Row":"A04","Material question and finding location":"Payment collection/distribution boundary. Actor/authority findings; Scenarios 1 and 6.","Status and exact claim IDs":"partial — C007–C009, C026, C029, C051","Missing evidence / next focused action":"Reopen fully updated NPS law, directives, individual PDA conditions and client-funds rules; those substantive protections remain deferred."},"raw_table_index":12,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"A05 Natural person, sole trader and juristic person/business borrower. Credit-classification findings; Scenario 5.","researcher_record":{"Row":"A05","Material question and finding location":"Natural person, sole trader and juristic person/business borrower. Credit-classification findings; Scenario 5.","Status and exact claim IDs":"partial — C014, C015, C043","Missing evidence / next focused action":"Apply definitions to each actual agreement; establish 2026 threshold notice chain and sole-trader contracting capacity."},"raw_table_index":12,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"A06 Guarantor, surety, joint borrower and director signature. Scenario 5.","researcher_record":{"Row":"A06","Material question and finding location":"Guarantor, surety, joint borrower and director signature. Scenario 5.","Status and exact claim IDs":"partial — C016, C044","Missing evidence / next focused action":"Read actual borrower/guarantee/security instruments; review precise current guarantee and joint-application rules."},"raw_table_index":12,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"A07 Secured/mortgage versus incidental/other debts. Credit classification; Scenario 5.","researcher_record":{"Row":"A07","Material question and finding location":"Secured/mortgage versus incidental/other debts. Credit classification; Scenario 5.","Status and exact claim IDs":"partial — C017, C018","Missing evidence / next focused action":"Product-by-product coverage and special remedies deferred; no all-debt debt-review claim."},"raw_table_index":12,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"A08 Creditor’s own account versus third-party collector/purchaser. Scenario 3.","researcher_record":{"Row":"A08","Material question and finding location":"Creditor’s own account versus third-party collector/purchaser. Scenario 3.","Status and exact claim IDs":"partial — C010–C012, C037, C050","Missing evidence / next focused action":"Specific assignment, factoring, remuneration, creditor mandate and applicable exemption must be read."},"raw_table_index":12,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"A09 Attorney/professional and FAIS perimeter. Actor matrix; Scenario 2.","researcher_record":{"Row":"A09","Material question and finding location":"Attorney/professional and FAIS perimeter. Actor matrix; Scenario 2.","Status and exact claim IDs":"partial — C013, C028, C035, C047","Missing evidence / next focused action":"Read full currently amended FAIS §7/exemptions; classify reserved legal activity and effective LPA sections."},"raw_table_index":12,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"A10 2026 amendment/commencement/transitional screen. Temporal findings and source register.","researcher_record":{"Row":"A10","Material question and finding location":"2026 amendment/commencement/transitional screen. Temporal findings and source register.","Status and exact claim IDs":"partial — C032, C033, C045","Missing evidence / next focused action":"Obtain official full proclamation/amendment chains for 2019 debt intervention, NCA regulations, thresholds, FAIS and NPS."},"raw_table_index":12,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"A11 Unauthorized-activity consequences. Registration findings; Scenario 1.","researcher_record":{"Row":"A11","Material question and finding location":"Unauthorized-activity consequences. Registration findings; Scenario 1.","Status and exact claim IDs":"partial — C002, C012, C034, C053","Missing evidence / next focused action":"Pin each violation to current element, enforcement body and actual remedy. No automatic debt/security/judgment extinction."},"raw_table_index":12,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"A12 Commercial company/CIPC/trade name versus regulatory permissions. Actor/authority findings; Scenario 6.","researcher_record":{"Row":"A12","Material question and finding location":"Commercial company/CIPC/trade name versus regulatory permissions. Actor/authority findings; Scenario 6.","Status and exact claim IDs":"answered — C001, C008, C022, C057","Missing evidence / next focused action":"In a later real examination match separately each permission to the correct individual/entity and effective date."},"raw_table_index":12,"coordinator_acceptance":"scoped_findings_traceability_checked_not_country_acceptance","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"A13 Foreign remote offering/advertising/nexus. Scenario 4.","researcher_record":{"Row":"A13","Material question and finding location":"Foreign remote offering/advertising/nexus. Scenario 4.","Status and exact claim IDs":"unresolved — C014, C029, C031","Missing evidence / next focused action":"Read targeted NCA cross-border, relevant professional, payments, establishment and advertising rules for actual country/service/funds facts."},"raw_table_index":12,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"A14 Formal debt review versus debt intervention. Statutory comparison.","researcher_record":{"Row":"A14","Material question and finding location":"Formal debt review versus debt intervention. Statutory comparison.","Status and exact claim IDs":"partial — C032, C038, C045","Missing evidence / next focused action":"Obtain and read an operative presidential proclamation (if any) and all associated regulations; no current benefit represented."},"raw_table_index":12,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"B01 Commercial debtor-paid negotiator — Scenarios 1 and 3; activity matrix.","researcher_record":{"Row":"B01","Actor and finding location":"Commercial debtor-paid negotiator — Scenarios 1 and 3; activity matrix.","Status and exact claim IDs":"partial — C003, C005, C028","Missing evidence / next focused action":"Determine whether the firm crosses §86, legal-practice, regulated product or money-handling boundaries in the exact engagement."},"raw_table_index":13,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"B02 Personally registered NCR debt counsellor — Scenario 1.","researcher_record":{"Row":"B02","Actor and finding location":"Personally registered NCR debt counsellor — Scenario 1.","Status and exact claim IDs":"answered — C001–C004, C024","Missing evidence / next focused action":"Individual status/conditions not actually checked; identify which substantive tasks are performed."},"raw_table_index":13,"coordinator_acceptance":"scoped_findings_traceability_checked_not_country_acceptance","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"B03 Debt-counselling company, employees and representatives — Scenarios 1–2.","researcher_record":{"Row":"B03","Actor and finding location":"Debt-counselling company, employees and representatives — Scenarios 1–2.","Status and exact claim IDs":"partial — C004, C054, C057","Missing evidence / next focused action":"Obtain actual task chart, employment/agency authority, named registration and relevant conditions if authorised in later work."},"raw_table_index":13,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"B04 Free/nonprofit/charity/consumer organisation — Scenario 2.","researcher_record":{"Row":"B04","Actor and finding location":"Free/nonprofit/charity/consumer organisation — Scenario 2.","Status and exact claim IDs":"partial — C005, C036, C050","Missing evidence / next focused action":"Test true activity, donations, indirect benefit and any expressly issued exemption; no blanket nonprofit exception."},"raw_table_index":13,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"B05 Attorney and advocate — professional actor findings.","researcher_record":{"Row":"B05","Actor and finding location":"Attorney and advocate — professional actor findings.","Status and exact claim IDs":"partial — C013, C035, C036","Missing evidence / next focused action":"Read applicable professional practice/admission rules and precise reserved service, mandate and practice structure."},"raw_table_index":13,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"B06 Accountant/other professional — Scenario 2.","researcher_record":{"Row":"B06","Actor and finding location":"Accountant/other professional — Scenario 2.","Status and exact claim IDs":"partial — C005, C028, C036","Missing evidence / next focused action":"Identify profession-specific statute, actual legal/financial advice and remuneration before claiming an exemption or additional authorisation."},"raw_table_index":13,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"B07 Creditor recovering its own claim — Scenario 3.","researcher_record":{"Row":"B07","Actor and finding location":"Creditor recovering its own claim — Scenario 3.","Status and exact claim IDs":"partial — C010, C037","Missing evidence / next focused action":"Separate ownership and collection for another; check credit-provider/NCA duties in a later conduct pass."},"raw_table_index":13,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"B08 Debt collector or collection company/personnel — Scenario 3.","researcher_record":{"Row":"B08","Actor and finding location":"Debt collector or collection company/personnel — Scenario 3.","Status and exact claim IDs":"partial — C010–C012, C027, C050","Missing evidence / next focused action":"Apply registration/exceptions to each statutory role; current fee tariff is not debtor-side advocacy permission."},"raw_table_index":13,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"B09 Debt purchaser and servicer — Scenario 3.","researcher_record":{"Row":"B09","Actor and finding location":"Debt purchaser and servicer — Scenario 3.","Status and exact claim IDs":"partial — C010, C037","Missing evidence / next focused action":"Read assignment, overdue status, acquisition purpose, factoring exception and servicing mandate."},"raw_table_index":13,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"B10 Referrer, lead generator or software-only supplier — activity findings.","researcher_record":{"Row":"B10","Actor and finding location":"Referrer, lead generator or software-only supplier — activity findings.","Status and exact claim IDs":"partial — C005, C055","Missing evidence / next focused action":"Examine workflow, who decides/communicates proposals, compensation and whether money or client mandates pass through the intermediary."},"raw_table_index":13,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"B11 PDA and staff — capacity findings.","researcher_record":{"Row":"B11","Actor and finding location":"PDA and staff — capacity findings.","Status and exact claim IDs":"partial — C007–C009, C026, C051","Missing evidence / next focused action":"Operational category substantially identified; actual employee qualifications, full conditions and funds protection not cleared."},"raw_table_index":13,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"B12 Public adviser/public authority — authority matrix.","researcher_record":{"Row":"B12","Actor and finding location":"Public adviser/public authority — authority matrix.","Status and exact claim IDs":"partial — C023, C036, C038","Missing evidence / next focused action":"Read precise statutory public-office functions/agency mandate. Official status alone is no blanket exception for outside commercial functions."},"raw_table_index":13,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"B13 Court administrator — Scenario 6.","researcher_record":{"Row":"B13","Actor and finding location":"Court administrator — Scenario 6.","Status and exact claim IDs":"partial — C020, C041","Missing evidence / next focused action":"Actual court appointment/order, qualifications and security; full administration-order procedure deferred."},"raw_table_index":13,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"B14 Trustee, liquidator or estate officer — Scenario 6.","researcher_record":{"Row":"B14","Actor and finding location":"Trustee, liquidator or estate officer — Scenario 6.","Status and exact claim IDs":"partial — C021","Missing evidence / next focused action":"Insolvency trustee body and Master read; separate company-liquidator appointment and operative statutory powers require a focused reading."},"raw_table_index":13,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"B15 Business-rescue practitioner — Scenario 6.","researcher_record":{"Row":"B15","Actor and finding location":"Business-rescue practitioner — Scenario 6.","Status and exact claim IDs":"partial — C022, C042, C057","Missing evidence / next focused action":"Obtain current Companies Act §138 body, CIPC conditions and actual appointment route."},"raw_table_index":13,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"B16 Direct fee/indirect commission/benefit — Scenarios 2–3.","researcher_record":{"Row":"B16","Actor and finding location":"Direct fee/indirect commission/benefit — Scenarios 2–3.","Status and exact claim IDs":"partial — C005, C010, C028, C036, C055","Missing evidence / next focused action":"Read compensation arrangements and match statute-specific “reward,” advice/intermediation and professional tests; consumer fee rules deferred."},"raw_table_index":13,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"B17 Qualification, fitness, resources and training — NCR/DC/PDA findings.","researcher_record":{"Row":"B17","Actor and finding location":"Qualification, fitness, resources and training — NCR/DC/PDA findings.","Status and exact claim IDs":"partial — C008, C024, C026, C048","Missing evidence / next focused action":"Current complete regulation 10 and individual conditions; verify dated 2024/25 qualification description against any later final rules."},"raw_table_index":13,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"B18 Nonprofit, professional, employment and ministerial exceptions — Scenario 2.","researcher_record":{"Row":"B18","Actor and finding location":"Nonprofit, professional, employment and ministerial exceptions — Scenario 2.","Status and exact claim IDs":"partial — C004, C036, C050, C054","Missing evidence / next focused action":"Locate actual exemption instrument or express applicable provision, with its beneficiary and scope; no global exception established."},"raw_table_index":13,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"COV-C01 NCR registers/supervises NCA debt counsellors and PDAs — authority matrix.","researcher_record":{"Row":"COV-C01","Authority or requirement; finding location":"NCR registers/supervises NCA debt counsellors and PDAs — authority matrix.","Status and exact claim IDs":"answered — C001, C007, C023, C039","Missing evidence / next focused action":"Actual status/conditions to be verified only if a later authorised named check is requested."},"raw_table_index":14,"coordinator_acceptance":"scoped_findings_traceability_checked_not_country_acceptance","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"COV-C02 National Consumer Tribunal/court statutory decision roles — Scenario 1, §86 pathway.","researcher_record":{"Row":"COV-C02","Authority or requirement; finding location":"National Consumer Tribunal/court statutory decision roles — Scenario 1, §86 pathway.","Status and exact claim IDs":"partial — C006, C038, C046","Missing evidence / next focused action":"Proceeding-specific jurisdiction, application, effect, standing and judicial orders deferred."},"raw_table_index":14,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"COV-C03 Council for Debt Collectors — Scenario 3.","researcher_record":{"Row":"COV-C03","Authority or requirement; finding location":"Council for Debt Collectors — Scenario 3.","Status and exact claim IDs":"answered — C010–C012, C056","Missing evidence / next focused action":"Actual role and registration not searched; current exceptions/conditions require case facts."},"raw_table_index":14,"coordinator_acceptance":"scoped_findings_traceability_checked_not_country_acceptance","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"COV-C04 Legal Practice Council — professional route.","researcher_record":{"Row":"COV-C04","Authority or requirement; finding location":"Legal Practice Council — professional route.","Status and exact claim IDs":"partial — C013, C035, C056","Missing evidence / next focused action":"Current admission/practice rules and any clinic-specific permission in actual transaction."},"raw_table_index":14,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"COV-C05 FSCA/FSP/representative route — authority matrix.","researcher_record":{"Row":"COV-C05","Authority or requirement; finding location":"FSCA/FSP/representative route — authority matrix.","Status and exact claim IDs":"partial — C028, C047","Missing evidence / next focused action":"Read current full FAIS text, defined product schedule, FSP category, representative and exemptions."},"raw_table_index":14,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"COV-C06 SARB/NPS, PSMB transition and other participant requirements — payment authority.","researcher_record":{"Row":"COV-C06","Authority or requirement; finding location":"SARB/NPS, PSMB transition and other participant requirements — payment authority.","Status and exact claim IDs":"partial — C029, C030, C053","Missing evidence / next focused action":"Full post-2026 operative NPS text/directives and classification of actual provider/payment operations."},"raw_table_index":14,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"COV-C07 Court/Master/CIPC appointments — Scenario 6.","researcher_record":{"Row":"COV-C07","Authority or requirement; finding location":"Court/Master/CIPC appointments — Scenario 6.","Status and exact claim IDs":"partial — C020–C022, C041–C042","Missing evidence / next focused action":"Verify current Companies Act and each actual appointment instrument, not just a professional register."},"raw_table_index":14,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"COV-C08 CIPC incorporation versus specialist authorisation — company boundary.","researcher_record":{"Row":"COV-C08","Authority or requirement; finding location":"CIPC incorporation versus specialist authorisation — company boundary.","Status and exact claim IDs":"answered — C022, C057","Missing evidence / next focused action":"Any actual company’s category, licence and practitioner identity require separate checks."},"raw_table_index":14,"coordinator_acceptance":"scoped_findings_traceability_checked_not_country_acceptance","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"COV-C09 NCR individual and PDA entity/capacity differentiation — authority matrix.","researcher_record":{"Row":"COV-C09","Authority or requirement; finding location":"NCR individual and PDA entity/capacity differentiation — authority matrix.","Status and exact claim IDs":"answered — C001, C007–C008, C054","Missing evidence / next focused action":"Independent entity/individual status, representative tasks and registration conditions not checked."},"raw_table_index":14,"coordinator_acceptance":"scoped_findings_traceability_checked_not_country_acceptance","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"COV-C10 PDA regulatory capital/insurance — quantitative Example B.","researcher_record":{"Row":"COV-C10","Authority or requirement; finding location":"PDA regulatory capital/insurance — quantitative Example B.","Status and exact claim IDs":"partial — C026, C040, C051","Missing evidence / next focused action":"Actual policy wording, aggregate exposure, legally sufficient cover, current conditions and financial-resource evidence."},"raw_table_index":14,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"COV-C11 Application/registration/branch/periodic charges — Examples A–B.","researcher_record":{"Row":"COV-C11","Authority or requirement; finding location":"Application/registration/branch/periodic charges — Examples A–B.","Status and exact claim IDs":"partial — C025, C040, C049","Missing evidence / next focused action":"Full current fee amendment chain and any current renewal/agency tariff; the 2016 example remains dated."},"raw_table_index":14,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"COV-C12 Foreign operation/recognition/establishment — Scenario 4.","researcher_record":{"Row":"COV-C12","Authority or requirement; finding location":"Foreign operation/recognition/establishment — Scenario 4.","Status and exact claim IDs":"unresolved — C031, C057","Missing evidence / next focused action":"Specific foreign-to-South-Africa statutory nexus, professional recognition, permanent establishment and advertised service tests."},"raw_table_index":14,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"COV-C13 National registration effect versus provinces/locality — geographic register below.","researcher_record":{"Row":"COV-C13","Authority or requirement; finding location":"National registration effect versus provinces/locality — geographic register below.","Status and exact claim IDs":"partial — C023, C052","Missing evidence / next focused action":"Separate operative provincial/local law research in all nine provinces; no invented provincial debt-counsellor licence."},"raw_table_index":14,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"D01 Official public registration/status categories — five-step verification workflow.","researcher_record":{"Row":"D01","Verification subject and finding location":"Official public registration/status categories — five-step verification workflow.","Status and exact claim IDs":"answered — C039, C056","Missing evidence / next focused action":"Actual named search deliberately not performed; future lookup must preserve query date, category and restrictions."},"raw_table_index":15,"coordinator_acceptance":"scoped_findings_traceability_checked_not_country_acceptance","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"D02 Professional enrolment and statutory appointment — workflow; Scenario 6.","researcher_record":{"Row":"D02","Verification subject and finding location":"Professional enrolment and statutory appointment — workflow; Scenario 6.","Status and exact claim IDs":"partial — C035, C041–C042, C056","Missing evidence / next focused action":"Current practising status, actual court/Master/CIPC appointment and any limits; no actual person checked."},"raw_table_index":15,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"D03 Minimum documentary classification packet — workflow and all scenarios.","researcher_record":{"Row":"D03","Verification subject and finding location":"Minimum documentary classification packet — workflow and all scenarios.","Status and exact claim IDs":"answered — C014–C018, C031, C037, C044, C055–C057","Missing evidence / next focused action":"Collect only if separately authorised later: agreements, capacity, services, remuneration, mandate, registration, funds flow."},"raw_table_index":15,"coordinator_acceptance":"scoped_findings_traceability_checked_not_country_acceptance","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"D04 Verification limits: permission ≠ contract/outcome — workflow.","researcher_record":{"Row":"D04","Verification subject and finding location":"Verification limits: permission ≠ contract/outcome — workflow.","Status and exact claim IDs":"answered — C034, C039, C056","Missing evidence / next focused action":"Creditor assent and actual contract terms remain unavailable; no outcome promises."},"raw_table_index":15,"coordinator_acceptance":"scoped_findings_traceability_checked_not_country_acceptance","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"D05 Unauthorized acts and available legal consequences — Scenario 1.","researcher_record":{"Row":"D05","Verification subject and finding location":"Unauthorized acts and available legal consequences — Scenario 1.","Status and exact claim IDs":"partial — C002, C012, C034, C053","Missing evidence / next focused action":"Exact element, version, regulator process and remedies; consumer-specific redress deferred."},"raw_table_index":15,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"D06 Official general precedent/enforcement text — researcher limitations.","researcher_record":{"Row":"D06","Verification subject and finding location":"Official general precedent/enforcement text — researcher limitations.","Status and exact claim IDs":"unresolved — C002, C012, C034","Missing evidence / next focused action":"NCR annual report’s outcomes are summaries, not read primary Tribunal decisions. Future narrow official-judgment reading must record posture, holding, pinpoints and amendments. No full citator/nonexistence claim."},"raw_table_index":15,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"D07 Private contracts, terms and consent — hypothetical documentation.","researcher_record":{"Row":"D07","Verification subject and finding location":"Private contracts, terms and consent — hypothetical documentation.","Status and exact claim IDs":"unresolved — C005, C037, C055–C056","Missing evidence / next focused action":"No real service contract, assignment, consent, insurance policy or lender arrangement obtained; must not infer provisions."},"raw_table_index":15,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"D08 Published template versus operative permission — S033 and workflow.","researcher_record":{"Row":"D08","Verification subject and finding location":"Published template versus operative permission — S033 and workflow.","Status and exact claim IDs":"answered — C042, C056–C057","Missing evidence / next focused action":"A 2011 issuer form proves its own published text/version only; not a current application or appointment."},"raw_table_index":15,"coordinator_acceptance":"scoped_findings_traceability_checked_not_country_acceptance","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"E01 Private voluntary workout versus §86/§87 debt review. Scenario 1 and 3.","researcher_record":{"Row":"E01","Narrow mechanism or output":"Private voluntary workout versus §86/§87 debt review. Scenario 1 and 3.","Status and exact claim IDs":"answered — C005–C006, C038, C046","Missing evidence / next focused action":"Actual eligibility, procedural protection and order effects deferred."},"raw_table_index":16,"coordinator_acceptance":"scoped_findings_traceability_checked_not_country_acceptance","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"E02 Registered counsellor, NCR, Tribunal and court roles. Statutory pathway.","researcher_record":{"Row":"E02","Narrow mechanism or output":"Registered counsellor, NCR, Tribunal and court roles. Statutory pathway.","Status and exact claim IDs":"partial — C001, C006, C023, C038","Missing evidence / next focused action":"Detailed competence/appeals/procedure/status effects reserved."},"raw_table_index":16,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"E03 Administration order as separate statutory route. Scenario 6.","researcher_record":{"Row":"E03","Narrow mechanism or output":"Administration order as separate statutory route. Scenario 6.","Status and exact claim IDs":"partial — C020, C041","Missing evidence / next focused action":"Full thresholds, eligible debts, forms, cost, security and post-order mechanics reserved."},"raw_table_index":16,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"E04 Sequestration/insolvency as separate route. Scenario 6.","researcher_record":{"Row":"E04","Narrow mechanism or output":"Sequestration/insolvency as separate route. Scenario 6.","Status and exact claim IDs":"partial — C021","Missing evidence / next focused action":"Full estate, priority, discharge, asset and tax rules reserved."},"raw_table_index":16,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"E05 Company business rescue as separate route. Scenario 6.","researcher_record":{"Row":"E05","Narrow mechanism or output":"Company business rescue as separate route. Scenario 6.","Status and exact claim IDs":"partial — C022, C042","Missing evidence / next focused action":"Currently amended §138 and full company rescue procedures reserved."},"raw_table_index":16,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"E06 Six capacity/classification scenarios with adverse branches. Scenarios 1–6.","researcher_record":{"Row":"E06","Narrow mechanism or output":"Six capacity/classification scenarios with adverse branches. Scenarios 1–6.","Status and exact claim IDs":"answered — C001–C009, C010–C022, C028–C031, C037–C044, C054–C057","Missing evidence / next focused action":"Hypotheticals are conditional; no specific party/provider/borrower eligibility concluded."},"raw_table_index":16,"coordinator_acceptance":"scoped_findings_traceability_checked_not_country_acceptance","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"E07 Two historical financial examples and one aggregate-insurance check. Examples A–B.","researcher_record":{"Row":"E07","Narrow mechanism or output":"Two historical financial examples and one aggregate-insurance check. Examples A–B.","Status and exact claim IDs":"answered for dated arithmetic; partial for present-day applicability — C025–C026, C040, C049, C051","Missing evidence / next focused action":"Recheck 2026 fee and safeguard chain before anyone uses the figures in an application."},"raw_table_index":16,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"E08 Complete debt-review and insolvency effects. Only narrow distinctions covered.","researcher_record":{"Row":"E08","Narrow mechanism or output":"Complete debt-review and insolvency effects. Only narrow distinctions covered.","Status and exact claim IDs":"excluded_with_reason — C006, C018, C020–C022, C038","Missing evidence / next focused action":"Separate full statutory-solution work; no broad-country A097 acceptance."},"raw_table_index":16,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"F01 Consumer fee earning and timing for debt counselling/private negotiation","researcher_record":{"Row":"F01","Deferred parent topic":"Consumer fee earning and timing for debt counselling/private negotiation","Status and boundary claim IDs":"excluded_with_reason — C025, C049","Exact next focused research question":"Which currently operative Act/regulation/NCR condition or valid guideline governs when each fee may be earned, charged or retained, for which service and person?"},"raw_table_index":17,"coordinator_acceptance":"deferred_parent_domain_not_accepted","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"F02 Consumer fee caps, refunds and cancellation","researcher_record":{"Row":"F02","Deferred parent topic":"Consumer fee caps, refunds and cancellation","Status and boundary claim IDs":"excluded_with_reason — C025, C027, C049","Exact next focused research question":"Separate any operative debt-counselling fee guideline, contractual/private-service fees and collector-side tariff; read triggers, cancellation/refund conditions and amendment history."},"raw_table_index":17,"coordinator_acceptance":"deferred_parent_domain_not_accepted","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"F03 Consumer contracts, disclosures, advertising and conduct","researcher_record":{"Row":"F03","Deferred parent topic":"Consumer contracts, disclosures, advertising and conduct","Status and boundary claim IDs":"excluded_with_reason — C002, C005, C056","Exact next focused research question":"What currently applicable NCA, consumer-protection, professional and contract requirements govern the exact advertised service and its written terms?"},"raw_table_index":17,"coordinator_acceptance":"deferred_parent_domain_not_accepted","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"F04 Client money, trust accounts and payment safeguarding","researcher_record":{"Row":"F04","Deferred parent topic":"Client money, trust accounts and payment safeguarding","Status and boundary claim IDs":"excluded_with_reason — C007–C009, C029, C051, C053","Exact next focused research question":"Map each account owner, beneficiary, custody interval, authorised payment category, reconciliations, indemnity, interest and permitted fund transfer under updated laws."},"raw_table_index":17,"coordinator_acceptance":"deferred_parent_domain_not_accepted","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"F05 Private remedies and contract claims","researcher_record":{"Row":"F05","Deferred parent topic":"Private remedies and contract claims","Status and boundary claim IDs":"excluded_with_reason — C012, C034, C056","Exact next focused research question":"What actual cause of action and remedy, against which actor, follows from proven facts? Distinguish provider liability from debt enforceability."},"raw_table_index":17,"coordinator_acceptance":"deferred_parent_domain_not_accepted","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"F06 Regulatory redress, complaints and enforcement","researcher_record":{"Row":"F06","Deferred parent topic":"Regulatory redress, complaints and enforcement","Status and boundary claim IDs":"excluded_with_reason — C002, C012, C023, C053","Exact next focused research question":"Identify current complaint channels, standing, jurisdiction, sanction elements, limitation and actual judicial/Tribunal remedies from operative primary law."},"raw_table_index":17,"coordinator_acceptance":"deferred_parent_domain_not_accepted","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"F07 Full debt-product catalogue","researcher_record":{"Row":"F07","Deferred parent topic":"Full debt-product catalogue","Status and boundary claim IDs":"excluded_with_reason — C014–C018","Exact next focused research question":"Classify every material credit and noncredit product, exclusions, contingent liabilities and special regimes, with current thresholds."},"raw_table_index":17,"coordinator_acceptance":"deferred_parent_domain_not_accepted","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"F08 Collection, validation and debt disputes","researcher_record":{"Row":"F08","Deferred parent topic":"Collection, validation and debt disputes","Status and boundary claim IDs":"excluded_with_reason — C010–C012, C027, C037","Exact next focused research question":"Read creditor/collector notices, proof, contested amounts, mandates and remedies under the exact applicable South African statute—not a foreign validation model."},"raw_table_index":17,"coordinator_acceptance":"deferred_parent_domain_not_accepted","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"F09 Prescription, limitation and revival","researcher_record":{"Row":"F09","Deferred parent topic":"Prescription, limitation and revival","Status and boundary claim IDs":"excluded_with_reason — C012, C018, C034","Exact next focused research question":"Read the operative Prescription Act and debt-specific exceptions, acknowledgments, judgments and transitional rules."},"raw_table_index":17,"coordinator_acceptance":"deferred_parent_domain_not_accepted","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"F10 Credit reporting, bureau disputes and clearance certificates","researcher_record":{"Row":"F10","Deferred parent topic":"Credit reporting, bureau disputes and clearance certificates","Status and boundary claim IDs":"excluded_with_reason — C038, C045","Exact next focused research question":"Read current NCA §§70–72, regulations and 2026 NCR guidance, including operative filing and dispute procedures; S037 is not a completed rules audit."},"raw_table_index":17,"coordinator_acceptance":"deferred_parent_domain_not_accepted","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"F11 Courts, service, default, judgments and enforcement","researcher_record":{"Row":"F11","Deferred parent topic":"Courts, service, default, judgments and enforcement","Status and boundary claim IDs":"excluded_with_reason — C019–C021, C034","Exact next focused research question":"Identify court/Tribunal competence, process commencement, proper service, orders, remedies and applicable procedural rules before stating effects."},"raw_table_index":17,"coordinator_acceptance":"deferred_parent_domain_not_accepted","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"F12 Enforcement exemptions, wages, bank accounts and assets","researcher_record":{"Row":"F12","Deferred parent topic":"Enforcement exemptions, wages, bank accounts and assets","Status and boundary claim IDs":"excluded_with_reason — C020–C021, C034","Exact next focused research question":"Read operative enforcement/protected-property legislation and applicable local forum rules for the type of debt/order."},"raw_table_index":17,"coordinator_acceptance":"deferred_parent_domain_not_accepted","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"F13 Mortgage, other secured debts and repossession","researcher_record":{"Row":"F13","Deferred parent topic":"Mortgage, other secured debts and repossession","Status and boundary claim IDs":"excluded_with_reason — C016–C017, C021","Exact next focused research question":"Analyse real-security instruments, foreclosure/repossession processes, ownership, priority and judicial protections separately."},"raw_table_index":17,"coordinator_acceptance":"deferred_parent_domain_not_accepted","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"F14 Rent, medical accounts and utilities","researcher_record":{"Row":"F14","Deferred parent topic":"Rent, medical accounts and utilities","Status and boundary claim IDs":"excluded_with_reason — C018","Exact next focused research question":"Determine which obligations are NCA credit agreements, statutory municipal/service obligations or ordinary contracts, and their distinct remedies."},"raw_table_index":17,"coordinator_acceptance":"deferred_parent_domain_not_accepted","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"F15 Maintenance/support, fines and criminal/public obligations","researcher_record":{"Row":"F15","Deferred parent topic":"Maintenance/support, fines and criminal/public obligations","Status and boundary claim IDs":"excluded_with_reason — C018, C021","Exact next focused research question":"Establish special statutory debt/collection and non-discharge regimes; no private workout generalisation."},"raw_table_index":17,"coordinator_acceptance":"deferred_parent_domain_not_accepted","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"F16 Tax, government debt and priority claims","researcher_record":{"Row":"F16","Deferred parent topic":"Tax, government debt and priority claims","Status and boundary claim IDs":"excluded_with_reason — C018, C021","Exact next focused research question":"Read applicable revenue, collection, administrative and insolvency priority law; separate taxpayer from company/estate capacity."},"raw_table_index":17,"coordinator_acceptance":"deferred_parent_domain_not_accepted","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"F17 Financial, nonprofit and public assistance","researcher_record":{"Row":"F17","Deferred parent topic":"Financial, nonprofit and public assistance","Status and boundary claim IDs":"excluded_with_reason — C005, C036","Exact next focused research question":"Identify actual public assistance programmes, eligibility, service mandates, effective dates and responsible bodies without assuming a blanket free-service exception."},"raw_table_index":17,"coordinator_acceptance":"deferred_parent_domain_not_accepted","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"F18 Full NCA debt-review eligibility, forms, stays, timelines and order effects","researcher_record":{"Row":"F18","Deferred parent topic":"Full NCA debt-review eligibility, forms, stays, timelines and order effects","Status and boundary claim IDs":"excluded_with_reason — C006, C019, C038, C046","Exact next focused research question":"Complete current §86/§87/regulation 24 and court/Tribunal procedural and subsequent-amendment analysis."},"raw_table_index":17,"coordinator_acceptance":"deferred_parent_domain_not_accepted","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"F19 Administration-order and insolvency/sequestration procedure, forms, costs, discharge and taxes","researcher_record":{"Row":"F19","Deferred parent topic":"Administration-order and insolvency/sequestration procedure, forms, costs, discharge and taxes","Status and boundary claim IDs":"excluded_with_reason — C020–C021, C041","Exact next focused research question":"Conduct a separate full statutory-solution study; present provider capacity here does not resolve debtor outcomes."},"raw_table_index":17,"coordinator_acceptance":"deferred_parent_domain_not_accepted","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"F20 Business-rescue company rights, votes, priority, rescue plan and costs","researcher_record":{"Row":"F20","Deferred parent topic":"Business-rescue company rights, votes, priority, rescue plan and costs","Status and boundary claim IDs":"excluded_with_reason — C022, C042","Exact next focused research question":"Read current Companies Act Chapter 6 and rules, including §138, in full."},"raw_table_index":17,"coordinator_acceptance":"deferred_parent_domain_not_accepted","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"F21 Foreign creditors, currency, governing law, jurisdiction, recognition, foreign assets and moving abroad — A098","researcher_record":{"Row":"F21","Deferred parent topic":"Foreign creditors, currency, governing law, jurisdiction, recognition, foreign assets and moving abroad — A098","Status and boundary claim IDs":"excluded_with_reason — C014, C031","Exact next focused research question":"Conduct the independent A098 cross-border report by transaction and jurisdiction; this pass only flags remote-provider nexus."},"raw_table_index":17,"coordinator_acceptance":"deferred_parent_domain_not_accepted","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"F22 Sector-specific rules, professional conduct and actual contract terms","researcher_record":{"Row":"F22","Deferred parent topic":"Sector-specific rules, professional conduct and actual contract terms","Status and boundary claim IDs":"excluded_with_reason — C013, C028, C035, C056","Exact next focused research question":"Obtain exact sector law/professional regulations and, if authorised later, actual mandates and contracts; none was privately obtained."},"raw_table_index":17,"coordinator_acceptance":"deferred_parent_domain_not_accepted","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"F23 Full legislative/source currentness across every relevant subject","researcher_record":{"Row":"F23","Deferred parent topic":"Full legislative/source currentness across every relevant subject","Status and boundary claim IDs":"partial — C025, C030, C032–C033, C043, C048–C049","Exact next focused research question":"Build provision-specific repeal/amendment/commencement timelines using Gazette notices; distinguish publication, guidance and effective date."},"raw_table_index":17,"coordinator_acceptance":"explicit_unresolved_or_partial_hold_preserved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"F24 All other countries and South Africa as a complete country root — A097","researcher_record":{"Row":"F24","Deferred parent topic":"All other countries and South Africa as a complete country root — A097","Status and boundary claim IDs":"excluded_with_reason — C014, C052","Exact next focused research question":"Independently research each country/remaining South African branch; no adoption or inference from foreign regimes."},"raw_table_index":17,"coordinator_acceptance":"deferred_parent_domain_not_accepted","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"Eastern Cape unresolved — C052 is national only","researcher_record":{"Province":"Eastern Cape","Geographic status and claim":"unresolved — C052 is national only","Exact next question; material not examined":"Do Eastern Cape operative provincial enactments or the actual municipality’s trade/advertising rules attach to a locally established debt-services business? Check official provincial gazettes and the municipality concerned; neither examined."},"raw_table_index":18,"coordinator_acceptance":"all_nine_provinces_and_local_rules_unresolved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"Free State unresolved — C052 national only","researcher_record":{"Province":"Free State","Geographic status and claim":"unresolved — C052 national only","Exact next question; material not examined":"Are any operative Free State provincial consumer/business provisions relevant to the defined actor or its premises? Read enacted text and effective dates; municipal rules unexamined."},"raw_table_index":18,"coordinator_acceptance":"all_nine_provinces_and_local_rules_unresolved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"Gauteng unresolved — C052 national only","researcher_record":{"Province":"Gauteng","Geographic status and claim":"unresolved — C052 national only","Exact next question; material not examined":"Does an actual Gauteng establishment or targeted activity engage provincial business regulation or relevant municipal rules in addition to NCR categories? No such legislation read."},"raw_table_index":18,"coordinator_acceptance":"all_nine_provinces_and_local_rules_unresolved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"KwaZulu-Natal unresolved — C052 national only","researcher_record":{"Province":"KwaZulu-Natal","Geographic status and claim":"unresolved — C052 national only","Exact next question; material not examined":"Which, if any, current KwaZulu-Natal provincial or applicable municipal requirements govern the specified commercial premises, solicitation or local operation? Official text unexamined."},"raw_table_index":18,"coordinator_acceptance":"all_nine_provinces_and_local_rules_unresolved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"Limpopo unresolved — C052 national only","researcher_record":{"Province":"Limpopo","Geographic status and claim":"unresolved — C052 national only","Exact next question; material not examined":"Is there operative provincial or location-specific regulation attaching to the business model, and what is its exact statutory trigger? No provincial gazette/locality reviewed."},"raw_table_index":18,"coordinator_acceptance":"all_nine_provinces_and_local_rules_unresolved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"Mpumalanga unresolved — C052 national only","researcher_record":{"Province":"Mpumalanga","Geographic status and claim":"unresolved — C052 national only","Exact next question; material not examined":"Does the provider’s actual establishment or service activity invoke provincial/local business rules beyond the national licences identified? Primary text not read."},"raw_table_index":18,"coordinator_acceptance":"all_nine_provinces_and_local_rules_unresolved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"Northern Cape unresolved — C052 national only","researcher_record":{"Province":"Northern Cape","Geographic status and claim":"unresolved — C052 national only","Exact next question; material not examined":"Are any relevant provincial enactments or actual municipality’s trade requirements triggered by the physical or remote operation? No official provincial/local body examined."},"raw_table_index":18,"coordinator_acceptance":"all_nine_provinces_and_local_rules_unresolved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"North West unresolved — C052 national only","researcher_record":{"Province":"North West","Geographic status and claim":"unresolved — C052 national only","Exact next question; material not examined":"Do North West provincial or municipal provisions add an applicable permission or condition for this exact business activity? No official text reviewed."},"raw_table_index":18,"coordinator_acceptance":"all_nine_provinces_and_local_rules_unresolved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."},{"topic":"Western Cape unresolved — C052 national only","researcher_record":{"Province":"Western Cape","Geographic status and claim":"unresolved — C052 national only","Exact next question; material not examined":"Is any operative Western Cape or relevant municipality-specific trade, business or advertising rule applicable to an identified office/service model? No enacted provincial/local provisions read."},"raw_table_index":18,"coordinator_acceptance":"all_nine_provinces_and_local_rules_unresolved","coordinator_review_file":"[internal evidence reference]","coordinator_review":"Exact researcher row, mapped claim context and next action retained. National gateway findings do not resolve provincial, current-law, contract or whole-country scope."}],"annotations":{},"corrections":[],"resolved_corrections":[],"review_history":[{"id":"C_ZA-pass-01-20261027-0013","status":"scoped_review_with_remaining_primary_currentness_contract_payment_professional_territorial_holds","at":"2026-10-27T00:08:34.702926+00:00"}]}