IEJ comments on proposed changes to grant applications, eligibility, verification, and payments
The Institute for Economic Justice (IEJ) has submitted comments on the draft social assistance regulations issued under the Social Assistance Act. The proposed amendments relate to applications, payments, eligibility requirements, identity and life verification, and the circumstances under which social grants may be suspended, allowed to lapse, or cancelled.
The submission argues that the amendments must be considered against significant recent changes to grant administration by the South African Social Security Agency (SASSA). These include intensified grant reviews, automated checks of applicants’ personal and financial information, biometric identity verification, increasing digitalisation, and the planned termination of Postbank’s role in distributing social grants.
Grant reviews driven by savings targets
National Treasury has imposed conditions on SASSA’s operating budget that require the agency to intensify the verification and review of grant applicants and recipients. These measures are intended to produce savings of R2 billion in the current financial year and R1 billion in the following year by reducing the number of grants in payment.
The IEJ argues that these targets are arbitrary and are not supported by evidence about the prevalence of fraud or ineligible grant recipients. SASSA has also not received the additional resources it would need to undertake reviews on this scale fairly and efficiently.
In practice, many grants have been cancelled because recipients could not complete the review process, rather than because they were found to be ineligible. Transport costs, inaccessible communications, physical limitations, and extremely long queues at under-resourced SASSA offices create serious barriers, particularly for older people, persons with disabilities, rural residents, and other vulnerable applicants and recipients.
Unreliable data and automated decision-making
SASSA uses information from credit bureaus, public databases, and bank accounts to identify grant recipients for review. The IEJ warns that these sources can be outdated, incomplete, or misleading. Bank deposits, for example, do not necessarily constitute personal income and may include money held on behalf of someone else, including child maintenance payments.
These automated checks can incorrectly flag eligible people and contribute to the suspension or cancellation of grants on unreliable grounds. The submission recommends that eligibility should primarily be established through self-declaration and relevant supporting documentation, accompanied by random, human-led audits where necessary.
Digitalisation must improve access
Digital systems can make social grant administration more efficient and accessible, but only if they are designed around the needs and circumstances of grant applicants. The submission warns that digitalisation is increasingly being used to reduce administrative costs, even where it creates new barriers to accessing social assistance.
People who lack smartphones, stable internet connections, personal mobile numbers, digital literacy, or smart identity cards may be unable to complete online applications or biometric identity checks. The IEJ therefore calls for grant applicants and recipients to always have the option of receiving assistance from a person, either telephonically or in person.
No decision affecting access to social assistance should be made by an automated system without explainability, accountability, a clear avenue for appeal, and meaningful human oversight.
Concerns about the proposed amendments
The IEJ raises specific concerns about three proposed amendments:
- Regulation 13 would require grant recipients to produce valid identity documents within 180 days of approval. The IEJ warns that delays at the Department of Home Affairs could result in vulnerable people losing grants through no fault of their own.
- Regulation 15 would require recipients to notify SASSA of changes in their circumstances within 90 days, without clearly defining which changes must be reported or what the consequences of failing to report them would be.
- Regulation 30 would allow SASSA to use “any verifiable means” to establish whether a grant recipient is alive and “any means of communication” to require them to appear at an office. These broad provisions could expose recipients to suspension or cancellation based on unreliable verification or communications they never received.
The submission opposes amendments that could expand SASSA’s power to suspend or cancel grants without sufficiently clear, reasonable, and accountable safeguards.
Protecting access to social assistance
The IEJ calls for National Treasury’s conditions on SASSA’s budget to be withdrawn and for the grant review system to be reconsidered. Any verification process must be reasonable, evidence-based, contestable, and subject to public scrutiny.
The submission also calls for SASSA to be adequately resourced, for mandatory remote biometric verification to be abandoned, and for grant recipients to retain access to a publicly governed, non-commercial, and fee-free payment option. The IEJ recommends reinstating and adequately resourcing Postbank to perform this role.
Social grant administration should uphold the constitutional right to social assistance. Measures intended to improve efficiency or prevent fraud must not create new barriers that unfairly exclude eligible people from grants that may be their only means of survival.