Comments on Draft Regulations

A joint submission by the Institute for Economic Justice (IEJ) and the Socio-Economic Rights Institute (SERI) providing recommendations on the draft amendments to the regulations for the COVID-19 Social Relief of Distress (SRD) grant in South Africa.

• The authors argue that the current bank verification process is flawed because it treats all deposits as income, failing to account for money held for others or child maintenance. They recommend that personal information provided by applicants take precedence over bank checks and government databases, and that applicants be allowed to provide extenuating evidence during appeals.
• The submission recommends raising the means-test income threshold from R624 to R1335 (the Upper Bound Poverty Line) and indexing it to poverty lines to account for inflation. They further propose that this threshold be applied retrospectively to applications from April, May, and June.
• The authors call for the removal of the budget cap, noting that the Treasury's allocation for 10.5 million applicants is insufficient given that 18.3 million people live below the Food Poverty Line. They argue that capping the grant is inconsistent with the South African Constitution's needs-based approach to social assistance.
• The document highlights barriers to access, specifically criticizing the 'online-only' application process which excludes those with digital illiteracy or lack of internet access. Recommendations include allowing physical applications and ensuring that data and mobile phone costs do not act as barriers.
• The submission strongly opposes the 'work conditionality' clause, which requires recipients to not 'unreasonably refuse' employment or education. The authors argue this could lead to coercive or exploitative labour practices and call for the clause's deletion or a strict definition of 'reasonable'.
• The authors recommend reversing the decision to remove the South African Post Office (SAPO) as a payment access point, arguing that shifting payments to private supermarket chains limits accessibility and risks the exploitation of recipient data.
• Regarding the recovery of funds, the authors state that any recovery of illegitimately paid grants must not impact a recipient's current monthly entitlements and that no scenario should leave a recipient in debt to the Department of Social Development (DSD).

APA

Institute for Economic Justice (n.d.). Comments on Draft Regulations. https://www.iej.org.za/wp-content/uploads/2022/07/IEJSERI-Submission-to-DSD-on-SRD-Amendments.pdf

Chicago

Institute for Economic Justice. Comments on Draft Regulations. n.d. https://www.iej.org.za/wp-content/uploads/2022/07/IEJSERI-Submission-to-DSD-on-SRD-Amendments.pdf.

Wikipedia

{{cite press release |author=Institute for Economic Justice |title=Comments on Draft Regulations |url=https://www.iej.org.za/wp-content/uploads/2022/07/IEJSERI-Submission-to-DSD-on-SRD-Amendments.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{instituteforeconomicjusticendcomments, author = {{Institute for Economic Justice}}, title = {{Comments on Draft Regulations }}, publisher = {Institute for Economic Justice}, url = {https://www.iej.org.za/wp-content/uploads/2022/07/IEJSERI-Submission-to-DSD-on-SRD-Amendments.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }