The South African Reserve Bank issued nine exchange control circulars on 8 April, giving legal effect to draft measures released for public comment following the 2026 Budget.
The circulars implement a package of reforms aimed at updating thresholds, reducing administrative friction, and supporting cross-border activity, as signalled in the Budget.
The SARB published the draft circulars on 3 March for public comment.
In brief, the final circulars provide for:
Circular 6: Single discretionary allowance – Authorised Dealers
The annual single discretionary allowance (SDA) for resident individuals aged 18 and older is increased from R1 million to R2m, covering a wide range of transactions including travel, gifts, offshore investments, and transfers. The circular also updates multiple provisions in the Authorised Dealer Manual to reflect the higher limit across different use cases.
Circular 7: SDA – ADLAs
The same increase to R2m is applied within the framework for authorised dealers with limited authority (ADLAs), including bureaux de change and money transfer operators. The circular also introduces specific source-of-funds verification requirements, including a minimum threshold, reflecting a more explicit compliance framework for these entities.
Circular 8: Cash export limits – Authorised Dealers
The limit on South African banknotes that may be exported or imported by residents, non-residents, and travellers is increased from R25 000 to R100 000 per person. The circular amends several provisions in the Authorised Dealer Manual dealing with travel allowances, the cross-border movement of cash, and related reporting requirements.
Circular 9: Cash export limits – ADLAs
The same increase to R100 000 is implemented within the ADLA framework, ensuring consistency across different categories of authorised dealers, with corresponding amendments to the ADLA Manual.
Circular 10: Merchanting transactions
The permissible time lag between payment to a foreign supplier and receipt of funds from a foreign buyer in merchanting transactions is standardised to four months, replacing the previous system of shorter, jurisdiction-dependent timeframes. This simplifies administration for cross-border trade intermediaries.
Circular 11: Miscellaneous transfers
The threshold for certain payments to non-residents – including refunds, operational expenses, and other transactions not specifically categorised elsewhere – is increased from R100 000 to R200 000 per transaction. This reduces the need for case-by-case approvals while retaining documentary requirements.
Circular 12: Card-based cross-border payments
The limit for foreign currency payments via credit or debit cards for imports, services and subscriptions is increased from R50 000 to R100 000 per transaction. The prohibition on splitting transactions to circumvent the limit is retained, and reporting requirements remain in place.
Circular 13: CFC accounts – local foreign currency settlement
Authorised dealers are permitted to approve the extension or renewal of existing approvals for local settlement in foreign currency between residents via customer foreign currency (CFC) accounts, provided that the underlying conditions remain unchanged and prior terms have been complied with. This represents a targeted delegation of authority from the SARB.
Circular 14: Inward foreign loans and trade finance
The previous interest rate caps on inward foreign loans and trade finance facilities are removed. Authorised dealers may approve such borrowings if interest rates are market-related in the country of denomination or normal in the trade concerned, and all other prudential and reporting requirements – including those relating to transfer pricing – are met.
Refinements from draft to final
The final circulars closely mirror the draft proposals released in March. However, technical refinements were introduced following the consultation process:
- ADLA transactions (Circular 7): The draft circular required verification of source of funds above a specified threshold. The final circular reframes this as a risk-based requirement, to be applied in line with internal controls, while retaining a defined minimum threshold.
- CFC account approvals (Circular 13): The draft circular allowed authorised dealers to approve extensions of existing approvals. The final version clarifies that dealers may approve extensions or renewals and must first satisfy themselves that the underlying conditions remain unchanged and that prior requirements have been met.
- Foreign loans (Circular 14): The draft circular required that interest rates be “market related and/or normal in the trade concerned”. In the final version, this is refined to “market related in the country of denomination and/or normal in the trade concerned”, narrowing interpretation by anchoring pricing to the relevant jurisdiction.
- Related-party funding (Circular 14): The draft circular required authorised dealers to have regard to transfer pricing rules. The final version introduces a stronger obligation, requiring confirmation from senior management that transfer pricing documentation is maintained.
