ARTICLE
16 September 2025

When Will South Africa's NPS Bill Come Into Force? Navigating The Road To Implementation

E
ENS

Contributor

ENS is an independent law firm with over 200 years of experience. The firm has over 600 practitioners in 14 offices on the continent, in Ghana, Mauritius, Namibia, Rwanda, South Africa, Tanzania and Uganda.
The South African Reserve Bank ("the SARB") has repeatedly emphasised - most recently in its Vision 2025 document - that a modern, safe, and interoperable payment ecosystem is now a strategic imperative.
South Africa Finance and Banking

The South African Reserve Bank ("the SARB") has repeatedly emphasised - most recently in its Vision 2025 document - that a modern, safe, and interoperable payment ecosystem is now a strategic imperative. Interoperability, stronger consumer safeguards, and an explicit framework for the regulation of non-bank payment service providers are singled out in Vision 2025 as urgent policy outcomes. Against that backdrop, many market participants are asking when the long-awaited National Payment System Bill ("NPS Bill") will finally surface.

Although Parliamentary officials have confirmed that, as at the date of writing, the Bill has not yet been introduced in either the National Assembly ("NA") or the National Council of Provinces ("NCOP"), the messaging in the Vision 2025 document suggests that modernising South Africa's payment system is a priority.

Why imminent changes to the National Payment System appears likely

  • Vision 2025 Commitments

The SARB commits in Vision 2025 to "[d]raft the NPS Bill", which process will be complemented by existing standards, frameworks and position papers. The Vision 2025 document states that the "end date" of this activity was December 2020.

  • Regulatory sequencing

On 3 March 2025, SARB published a draft directive entitled 'Directive in respect of specific payment activities within the national payment system' simultaneously with a draft exemption notice entitled 'Designation by the Prudential Authority of specific activities conducted in the national payment system which shall be deemed not to constitute 'the business of a bank' under paragraph (cc) in section 1(1) of the Banks Act, 1990'.

The draft directive and draft exemption notice, once finalised, may constitute short-term measures to modernise the payments system pending the promulgation of the NPS Bill.

  • Regional and international pressures

South Africa's upcoming Financial Action Task Force follow-up review and the African Continental Free Trade Area payments initiative both assume a robust legal basis for non-bank payment provider regulation and cross-border interoperability. Policymakers therefore have external incentives to move quickly.

Once the Bill has been drafted, and is approved by Cabinet, it will be introduced in the NA and proceed through committee review, public consultation, and debates in both Houses of Parliament. This process typically takes several months. If the Bill is tabled in late 2025, it could be enacted by mid-2026, with operational provisions likely phased in over the following year to allow for industry adjustment.

In summary, while the National Payment System Bill has not yet been introduced in Parliament, large-scale changes to South Africa's national payment system are imminent. Once a draft of the Bill is approved by Cabinet, the legislative process is expected to take several months. However, the draft directive and draft exemption notice may soon be published in their final form – as these subordinate instruments are not required to follow the same parliamentary process as national legislation. Market participants should prepare for significant changes to the payments landscape in the near future.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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