Four years after the Financial Sector Conduct Authority proposed a Central Unclaimed Assets Fund, National Treasury has put forward a detailed model for centralising an estimated R88.56 billion in unclaimed financial assets across the financial sector.
Treasury does not propose establishing a standalone central fund. Instead, a central administrator would manage records, tracing, and claims, while qualifying unclaimed assets would be transferred to the Corporation for Public Deposits (CPD) for custody and investment.The CPD is a subsidiary of the South African Reserve Bank that manages deposits from public-sector entities.
The proposals are contained in the discussion paper A Framework to Centralise Unclaimed Financial Assets in South Africa, published on 20 August 2026. The paper builds on the FSCA’s 2022 discussion paper and its 2024 response to stakeholder comments and seeks public comment on the administrator’s structure and funding, possible limits on claims, and the phased extension of the framework across the financial sector.
A different structure from the FSCA’s Central Fund
The proposed framework retains the FSCA’s centralisation objective but divides the principal functions between two entities.
Under the FSCA’s 2022 proposal, a dedicated Central Unclaimed Assets Fund would have received and managed unclaimed assets, paid valid claims, and retained sufficient funds to meet future claims. Treasury instead proposes using the CPD for custody and investment, with a separate central administrator performing the administrative and customer-facing functions. The administrator could be a new independent entity or an existing institution or service provider with the required capabilities.
Because the CPD is currently authorised to receive deposits from public-sector institutions, the proposed arrangement would require enabling legislation or approval from the Minister of Finance for the central administrator to deposit unclaimed assets with it.
Treasury maintains that the transfer would not amount to an appropriation of the assets because they would remain the property of potential claimants until the prescribed claims period expired.
The difference is institutional rather than a rejection of asset centralisation. Treasury’s discussion paper says qualifying assets would move from the balance sheets of the financial institutions holding them to the CPD, where they would be invested within the CPD’s permissible mandate.
This approach was foreshadowed in the February 2026 Budget Review, which said the government intended to centralise the management and investment of unclaimed financial assets. It envisaged transferring the assets to a central manager and appointing a separate central administrator responsible for administration, record-keeping, and tracing.
However, Treasury used different terminology earlier this month. In Moonstone’s 3 August article, “Unclaimed retirement benefits: a problem that won’t go away”, Alvinah Thela, National Treasury’s chief director for financial sector development, was quoted as saying: “Our thoughts are correctly around centralising but not having a central fund.”
The discussion paper does not propose the standalone statutory fund envisaged by the FSCA. Nevertheless, it goes beyond centralised record-keeping, tracing, and claims administration because the underlying assets would be compulsorily transferred and invested through the CPD. This raises the question of how Treasury distinguishes its proposed arrangement, in substance, from a central fund.
Retirement benefits would be the first phase
The reforms would be introduced in phases, beginning with unclaimed retirement benefits before being extended to other financial assets. Treasury regards the retirement-fund sector as the appropriate starting point because its systems for identifying and monitoring unclaimed benefits are more developed than those in other sectors.
During the first phase, the central administrator would build and maintain a consolidated dataset of unclaimed retirement benefits, co-ordinate tracing, operate a public-facing portal, and process claims. Qualifying benefits would be transferred through the administrator and deposited with the CPD.
The second phase would extend the framework to dormant bank accounts and unclaimed insurance and investment proceeds once the necessary definitions, transfer triggers, reporting standards, and legislative amendments had been developed.
For retirement benefits, the proposal would change where qualifying unclaimed assets are ultimately held and invested. Under the current framework, unclaimed benefits may be held in occupational funds or transferred to registered unclaimed benefit funds within the retirement-fund system. Under Treasury’s proposal, qualifying benefits would instead be transferred to the central administrator and deposited with the CPD.
What counts as an unclaimed asset remains to be settled
Before assets can be transferred into the centralised system, Treasury will have to determine when they qualify as unclaimed.
The Pension Funds Act already defines an unclaimed retirement benefit as a benefit that remains unpaid or unclaimed for 24 months after it became legally due and payable. Treasury is consulting on whether this definition could be applied across the wider financial sector.
A uniform definition may be difficult to apply to products with different contractual features. A retirement benefit or insurance policy may become payable after an identifiable event, whereas an open-ended bank or investment account may have no fixed maturity date. The FSCA’s earlier work therefore distinguished between dormant accounts, lost accounts, and unclaimed assets and recognised that definitions and trigger events may have to be tailored to different asset classes.
Treasury is also seeking views on whether uniform minimum standards for tracing, contact, and reporting would be feasible across the financial sector. The final definitions and transfer triggers will be important because they will determine when an institution must stop treating an asset under its existing arrangements and transfer it into the centralised system.
When would an asset become unclaimed?
A further issue Treasury is asking stakeholders to consider is the point at which an asset should be classified as unclaimed. The discussion paper notes that the financial sector currently applies different definitions and triggers and proposes a more consistent approach across asset classes.
For retirement benefits, Treasury is considering whether the 24-month period in the Pension Funds Act should provide the basis for a broader definition. Under the current retirement-fund framework, a benefit becomes unclaimed if it remains unpaid after the prescribed period, subject to the applicable tracing and other requirements. Treasury is asking whether a similar time-based trigger should apply to other categories of financial assets.
The question is important because the point at which an asset becomes legally “unclaimed” would determine when the central administrator’s responsibilities are triggered and when the asset could become subject to transfer to the centralised arrangement. Treasury is therefore seeking views on the appropriate definition, including whether a common definition should apply across the different sectors.
Treasury proposes a time limit on claims
One of the most significant differences between Treasury’s proposal and the FSCA’s 2022 model concerns how long owners and beneficiaries would have to claim an unclaimed asset.
The FSCA proposed that beneficial owners should retain the right to reclaim the value of their assets in perpetuity, together with accrued interest from the date of transfer. Treasury is now consulting on whether that right should expire after a prescribed period.
The discussion paper presents two options. Under the first, an asset would cease to be claimable when the owner reaches, or would have reached, 110 years of age. The owner’s age would determine the cut-off, but it would apply to claims submitted by both owners and beneficiaries. Under the second, the right to claim would expire 45 years after the asset first became unclaimed.
Treasury says a statutory limit would promote legal certainty, encourage timely claims, and reduce the costs associated with maintaining records and tracing people indefinitely. It says the 45-year option would be easier to administer because it would not require the administrator to determine or monitor the owner’s age. The paper also describes the 45-year option as providing greater administrative efficiency and certainty about the final disposition of assets, although Treasury is consulting on whether there should be a statutory limit at all.
Until the prescribed period expires, a valid claimant would be entitled to the net balance of the account, comprising the transferred amount and interest earned, less administration fees. Once the cut-off is reached, however, the owner and any beneficiary would lose the right to claim the asset.
The paper says assets that are no longer claimable should be used in accordance with an “approved CPD framework”, but it does not explain what that framework would entail or for what purposes the money could be used. This is separate from the proposed investment of assets while they remain claimable. Treasury says CPD investment could include government instruments, while the money remains available to satisfy valid claims.
Questions remain over safeguards, fees, and governance
The proposed transfer of unclaimed retirement benefits raises questions about the protections that would apply once the assets leave the retirement-fund system.
Treasury’s paper says the central arrangement should be supported by clear governance, regular reporting, transparency on fees and costs, and robust information-security and privacy controls. It proposes safeguards including authentication and access controls, audit trails, encryption, segregation of duties, and accountability for data breaches, aligned with the Protection of Personal Information Act and relevant cybersecurity standards.
The institutional form of the central administrator has not been settled. Treasury is considering either establishing a new independent entity or appointing an existing institution or service provider with the necessary capabilities. The administrator would be supervised by the FSCA, with service-level standards and sanctions also envisaged.
The administrator’s funding is another issue for consultation. Treasury proposes that its costs be recovered from the assets under administration but has invited stakeholders to suggest other funding models. This raises questions about how fees would be calculated and controlled, particularly for small balances, and whether the cost of central administration could erode the value ultimately paid to claimants.
The investment arrangements also warrant scrutiny. Treasury proposes that the CPD invest the transferred assets within its permissible mandate, including in government instruments. It says this would allow the money to contribute to national funding requirements while remaining available to meet valid claims. Any additional investment permissions required for the unclaimed-assets framework would have to be provided for in legislation.
Digital dashboard could help prevent future unclaimed benefits
The proposed reforms are not limited to dealing with the existing stock of unclaimed financial assets. Treasury is also considering measures that could reduce the number of retirement benefits becoming unclaimed in future.
A stakeholder working group chaired by the FSCA is examining the feasibility of a digital retirement dashboard that could give members easier access to information about their retirement savings. According to Treasury’s 20 August media statement announcing the discussion paper, the dashboard may help members to locate and track their benefits, improve data quality and efficiency in the retirement-fund industry, and reduce the risk of benefits becoming unclaimed.
The dashboard could therefore complement the proposed centralised system. A central administrator would maintain records, co-ordinate tracing, and process claims relating to assets classified as unclaimed, whereas easier access to current retirement information could help members keep track of benefits before they reach that point.
Consultation will shape the final model
The discussion paper does not represent a final framework. Treasury is seeking public comment on the structure and funding of the central administrator, the phased introduction of the system, minimum tracing and reporting standards, and whether there should be a statutory limit on claims.
Several elements will have to be settled before the system can be implemented. These include the administrator’s institutional form and governance, the mechanisms for transferring assets and information, the funding and fee structure, the period during which assets would remain claimable, and the treatment of assets after claimants’ rights expire.
The proposed framework is the latest stage of the policy process advanced by the FSCA’s 2022 discussion paper and subsequent response to stakeholder comments in 2024.
Treasury has changed the architecture by separating administration from custody and investment and proposing the CPD as the recipient and investment vehicle for transferred assets. The practical effect would nevertheless be to move qualifying unclaimed assets from the institutions holding them into a centralised system for administration, custody, and investment.
The consultation must therefore address not only how the new structure would operate, but whether its distinction from a central fund has substantive significance for the rights and protections of the people whose money it would hold.
Treasury is inviting written submissions by 19 September 2026. Responses should be limited to 10 pages and sent to Ms Alvinah Thela at retirementreform@treasury.gov.za.
