USER NOTICE – SARB DIRECTIVE NO 1 OF 2017, SECOND AMENDMENT
Following many years of time and capital investment by participants in the payments industry,
DebiCheck is approaching a key milestone date on 1 May 2021 as articulated in the SARB Directive 1 of
2017 as amended (The Directive).
Real Pay kept its Users updated throughout the project and ensured service availability alongside the
bank industry as it became available. This enabled our Users to evolve with the project and to be ready
and active in time. We acknowledge the significant effort of our Users to on-board onto DebiCheck and
to participate through mandate initiations and collections in the new stream.
This letter serves as a reminder and compliance notice to confirm the key requirements of the SARB
Directive 1 of 2017. In order to ensure compliant participation and continued access to the early window
collections in the National Payments System (NPS) the following key requirements include:
• No new origination of AEDO and NAEDO agreements from 1 May 2021 to 31 October 2021;
• Sunset date for AEDO and NAEDO is 31 October 2021;
• Existing AEDO and NAEDO contracts to be migrated prior to the sunset date; &
• Prior to the sunset date, AC/DebiCheck and AEDO payment instructions to be given processing
priority over NAEDO in the early processing window.
We confirm that the regulatory environment and industry seek to achieve the end state of the project.
The South African Reserve Bank has been focal and steadfast in its stance that the 1 May 2021 date will
not be shifting out.
We refer to The Directive (attached for your ease of reference) and specifically to clauses 5.1.3 – 5.1.4
in order to ensure your organisation’s current or future business practices are aligned with the
requirements. Contravention of the requirements in the Directive may lead to penalties and or
sanctions. We highlight that the obligation of Regulatory compliance requirements, of our Users, are
aligned with the signed Real Pay Contract.
Real Pay confirms its continuous efforts and input to PASA, PSSF and the Banks both on an individual as
well as an association level in order to address industry stability issues and User business contingency in
transition to the new payments stream.
The development of the Registered Mandate Service (RMS) is pivotal as a transition mechanism to
ensure business origination in the early window through the maturation of the new stream and the
associated milestone dates of 1 May 2021 and 31 October 2021. The SARB approved that this
mechanism forms part of transition and a modernised payments ecology. RMS allows the early
processing of collections where no response had been received from the account holder. RMS is
processed after DebiCheck and remain disputable as it is not authenticated.
It is important to note that in order to avail of RMS, Users (businesses) have to be registered and
onboarded onto DebiCheck. It requires the capability at User level to initiate DebiCheck transactions
through mandate initiation and transaction submissions. In the absence of this capability and the
attempted DebiCheck, beyond 1 May 2021, Users will only be able to collect on new contracts through
the normal debit order stream (EFT) processing late in the evening.
Real Pay has participated closely in the project and has been live with its sponsoring banks, Absa and
FNB since August 2018. Our position remains that onboarded Users should continue to initiate
DebiCheck transactions and incorporate and refine the learning practices in its internal processes. In
addition, migration of NAEDO transactions should continue. Key knowledge of data quality supports
internal process refinements and ensures optimal quality and the acceptance of data files with minimal
rejections. The majority of our Users already benefit from this approach with learning incorporated and
The benefits of readiness (onboarding) and participation are clear, as set out above and make for
origination of new contracts to proceed uninterrupted through the maturation and adoption stage of
The Real Pay Team