BUY NOW PAY LATER – SACRRA Roundtable Feedback
July 21, 2026
DCASA Member Feedback: CBA Engagement on the Debt Review Flag Removal Platform – August 2026
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Dear Members,
DCASA recently met with the Credit Bureau Association (CBA) to discuss the operation of the Debt Review Flag Removal Platform, current challenges experienced by Debt Counsellors, bureau alignment, fraud prevention, and opportunities to improve the debt review exit process.
The engagement was constructive and demonstrated the significant progress that has been made since the platform was launched. Below is a summary of the key discussions, guidance provided and matters that DCASA will continue pursuing on behalf of members.
Significant Improvement in Bureau Alignment
The CBA advised that when the platform was first introduced in March 2026, alignment between the five participating credit bureaux was approximately 37%, resulting in inconsistent responses and varying outcomes between bureaux.
Following weekly alignment meetings involving all participating bureaux, alignment has now improved to approximately 95% during May and June. Acceptance rates of submissions have similarly improved from approximately 90% in March to almost 99% during May.
The CBA confirmed that these weekly alignment sessions will continue to ensure that all bureaux apply the validation rules consistently and to resolve any discrepancies as they arise.
Compliance Obligations versus Bureau Requirements
An important distinction was made between the Debt Counsellor’s legal obligations under the National Credit Act and the operational responsibilities of the credit bureaux.
Debt Counsellors remain responsible for ensuring that:
- all debts included in debt review have been settled, prescribed or otherwise extinguished;
- the Debt Clearance Certificate has been correctly issued;
- the Debt Clearance Certificate aligns with the applicable Form 17.1 and/or court or consent order where applicable; and
- all legislative requirements have been met before issuing the Debt Clearance Certificate.
The CBA explained that the credit bureaux cannot verify these legal compliance requirements, as they do not receive court orders or Form 17.1 documentation and only have visibility of payment profile information submitted by participating SACCRA members.
Understanding What Appears on the Credit Bureau
Many queries relate to accounts that Debt Counsellors attempt to update but which do not appear on the consumer’s credit profile.
The CBA confirmed that credit bureaux only hold payment profile information submitted by participating SACCRA members. Accounts such as municipal accounts, school fees, certain micro lenders and other non-participating creditors may therefore never appear on the bureau despite forming part of the debt review.
Debt Counsellors are strongly encouraged to obtain an up-to-date credit profile before submitting amendments to determine exactly which accounts still require updating.
Submitting paid-up letters for accounts that do not appear on the bureau serves no purpose, as there is no corresponding bureau record to update.
Credit Provider Database
The CBA confirmed that every active SACCRA member submitting payment profile information is already loaded onto the CBA platform.
Where a credit provider cannot be located, Debt Counsellors should first:
- confirm that the account still appears on the latest credit profile; and
- confirm that the credit provider remains an active SACCRA member.
Where members identify examples of active bureau accounts that cannot be matched to a credit provider on the platform, these examples should be forwarded to the CBA at dcsupport@cba.co.za and cc alison@cba.co.za.
Debt Clearance Certificates
The CBA reiterated that Debt Clearance Certificates submitted through the platform must:
- be properly certified;
- be dated;
- contain the consumer’s correct details;
- clearly identify the consumer; and
- include all accounts that still require updating on the credit bureaux.
Incomplete or incorrectly certified certificates will continue to be rejected.
Paid-Up and Prescription Letters
Paid-up (or prescription) letters remain a requirement where accounts still reflect on the credit bureau.
Where an account no longer appears on the consumer’s credit profile, there is generally no requirement to obtain or upload a paid-up letter for that account.
The CBA also confirmed that considerable progress has been made following discussions with BASA and other credit providers regarding prescription letters. More accounts are now being updated directly with the bureaux, reducing reliance on manual documentation.
Where members continue receiving undated prescription letters or experience difficulties obtaining compliant documentation, these matters should continue to be escalated so that the CBA can engage directly with the relevant credit providers.
Debt Review Flag Removal Turnaround Times
The CBA confirmed the following process:
- The Debt Help System (DHS) should be updated at least three days before a submission is made through the CBA platform.
- Once all required documentation has been correctly submitted, bureaux should generally finalise amendments within approximately four business days.
Where a debt review flag remains active beyond this period despite all documentation having been accepted, the matter should be escalated for investigation.
Common Reasons for Rejections
The CBA identified several recurring issues that continue to delay processing:
- incorrectly certified Debt Clearance Certificates;
- certificates certified by unauthorised persons or relatives;
- submission of credit reports instead of Debt Clearance Certificates;
- If no Credit Providers can be allocated or no debts, a completed Clearance Certificate show casing no debt should be submitted together with a credit bureau report
- encrypted or password-protected paid-up letters; and
- incomplete supporting documentation.
DCASA has requested details of recurring submission errors so that targeted member guidance can be provided.
DCASA further raises concerns that additional credit bureau reports submission increases costs to the debt counsellors, it is our submission that consumers should cover these disbursements as these requirements does not form part of our DC fees.
Fraud Prevention
The fraud management process has now been significantly strengthened.
Where a bureau identifies a fraudulent document:
- a Code 11 rejection is issued;
- the Debt Counsellor’s access to the platform is automatically suspended;
- the NCR and all participating bureaux are immediately notified; and
- the matter is investigated.
Where the investigation confirms that the fraudulent document originated from the consumer and not the Debt Counsellor, access is restored and the Debt Counsellor may resubmit the application with valid documentation.
The process has now been largely automated to improve turnaround times and consistency.
Data Integrity Remains an Industry Priority
A significant discussion centred around responsibility for maintaining accurate credit information.
DCASA emphasised that responsibility for data integrity should ultimately remain with the credit provider, being the owner of the debt, rather than relying primarily on documentation submitted by Debt Counsellors.
Both organisations acknowledged that many of the current administrative requirements arise because of limitations within the National Credit Act rather than shortcomings of the platform itself.
There was broad agreement that future legislative reform should focus on:
- mandatory updating of bureau information by credit providers;
- improved data integrity;
- greater automation between credit providers and credit bureaux;
- reducing reliance on manual paid-up letters; and
- improving efficiencies throughout the debt review exit process.
These matters will continue to be raised through the Credit Industry Forum (CIF) and future legislative review processes.
Improvements to the CBA Platform
Following feedback from DCASA members, the CBA agreed to consider several enhancements to improve usability, including:
- introducing a Draft Save function before final submission;
- automatic deletion of draft applications after an agreed period;
- repositioning the Reset button to reduce accidental deletion of submissions; and
- improving the overall experience for smaller practices completing submissions manually.
The CBA explained that submitted applications cannot be edited because different credit bureaux process submissions at different times, and allowing amendments after submission would create inconsistencies between bureaux.
Technical Support
The CBA advised that very few genuine technical system issues are currently being experienced.
Most queries received relate to process guidance rather than platform failures.
Members experiencing unresolved issues should continue to email CBA Technical Support while copying Alison to ensure prompt investigation.
Ongoing Engagement
DCASA requested that quarterly engagement sessions be held with the CBA to discuss:
- bureau alignment statistics;
- recurring submission errors;
- platform enhancements;
- emerging operational issues; and
- future developments.
The CBA welcomed the proposal and committed to maintaining regular engagement with the industry.
DCASA’s Continued Engagement
While significant progress has been made since implementation of the platform, DCASA believes there remains considerable scope for improvement, particularly through legislative reform and stronger reporting obligations for credit providers.
DCASA will continue engaging with the CBA, NCR and the Credit Industry Forum to advocate for improvements that simplify the debt review exit process while maintaining the integrity of consumer credit information.
We appreciate the CBA’s openness during this engagement and acknowledge the considerable work undertaken to improve bureau alignment and platform functionality over recent months. DCASA will continue to provide members with updates as further developments arise.
