WRITTEN SUBMISSIONS: WATER SERVICES AMENDMENT BILL [B24 – 2025]

The Centre for Environmental Rights (CER) welcomes the introduction of a licensing regime and personal liability for directors in the Water Services Amendment Bill [B24 – 2025] but warns that the Bill concentrates too much power in the Director General and lacks mandatory environmental and public health standards for licensing. The CER argues that the Bill fails to address systemic under-funding of infrastructure and climate-change resilience, and it calls for the inclusion of mandatory climate-adaptation plans and a national framework for wastewater reuse.

• The proposed licensing regime for Water Services Providers (WSPs) lacks mandatory requirements for applicants to prove they can meet environmental and public-health standards, meaning a licence could be granted without evidence of the ability to supply safe drinking water or treat wastewater.
• The CER identifies a regulatory gap where the revocation or suspension of a licence under Section 22F does not legally obligate the provider to repair environmental damage, such as groundwater or river contamination, caused during their operations.
• The Bill concentrates policy formulation, regulation, licensing, and enforcement within the Director General of the Department of Water and Sanitation, which the CER argues risks administrative overload, inconsistent application, and politicisation.
• The CER expresses concern over the broad powers granted to 'authorised persons'—including search, seizure, and interrogation—noting a lack of clarity on supervision and the absence of a fast-track enforcement mechanism for acute public health threats or active pollution.
• The CER supports the introduction of personal liability for directors and municipal managers under Section 82A as a deterrent to promote legal compliance and prevent the pollution of water resources.
• The transitional arrangements, which include a 12-to-18 month licensing window and a six-month board replacement period, may be insufficient due to the administrative incapacity of many municipalities.
• The CER argues that the Bill does not address critical systemic issues such as chronic under-funding of bulk-water infrastructure, large-scale capital investment needs, or climate-adaptation planning.

APA

Centre for Environmental Rights (2026). WRITTEN SUBMISSIONS: WATER SERVICES AMENDMENT BILL [B24 – 2025]. https://cer.org.za/wp-content/uploads/2026/04/28-02-2026-CER-submissions-to-the-Water-Services-Amendment-Biil-B24_2025.pdf?x21779

Chicago

Centre for Environmental Rights. WRITTEN SUBMISSIONS: WATER SERVICES AMENDMENT BILL [B24 – 2025]. 2026. https://cer.org.za/wp-content/uploads/2026/04/28-02-2026-CER-submissions-to-the-Water-Services-Amendment-Biil-B24_2025.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=WRITTEN SUBMISSIONS: WATER SERVICES AMENDMENT BILL [B24 – 2025] |date=28 February 2026 |url=https://cer.org.za/wp-content/uploads/2026/04/28-02-2026-CER-submissions-to-the-Water-Services-Amendment-Biil-B24_2025.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2026written, author = {{Centre for Environmental Rights}}, title = {{WRITTEN SUBMISSIONS: WATER SERVICES AMENDMENT BILL [B24 – 2025]}}, publisher = {Centre for Environmental Rights}, year = {2026}, month = feb, url = {https://cer.org.za/wp-content/uploads/2026/04/28-02-2026-CER-submissions-to-the-Water-Services-Amendment-Biil-B24_2025.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }