DCASA on NCR Transfer Guideline 004/2026

By Casper le Grange
President: Debt Counsellors Association of South Africa (DCASA)

The Debt Counsellors Association of South Africa welcomes the National Credit Regulator’s continued focus on improving clarity in the debt review transfer process. The newly issued Debt Review Consumer Transfer Guideline 004/2026 provides important guidance to the industry and confirms the legal position regarding consumers who wish to transfer from one debt counsellor to another.

As DCASA, we support the principle that consumers must be able to exercise informed choice. A consumer should be able to transfer their debt review matter where there is a genuine need, including relocation, service difficulties, communication concerns, or where the consumer simply elects to be assisted by another registered debt counsellor.

At the same time, it is important that the transfer process remains clear, responsible and practical. Debt review is a formal process under the National Credit Act 34 of 2005, and in many cases the consumer’s debt review matter may already be subject to accepted proposals, court proceedings, a granted court order, payment arrangements through a registered Payment Distribution Agent, and credit bureau status updates.

A transfer is therefore not merely an administrative switch. It is the handover of a live legal and financial process.

Download the relevant documents

Download NCR Debt Review Consumer Transfer Guideline 004/2026:
DEBT REVIEW TRANSFER (JUNE 2026)

DCASA has submitted a response highliting that consumer education is of  importance. 

The consumer’s right to transfer

The NCR Guideline confirms that, in terms of section 86(1) of the National Credit Act, a consumer has the right to elect their debt counsellor. This includes the right to transfer from one registered debt counsellor to another.

DCASA supports this position. Consumer choice is an important part of a fair and transparent debt review system.

However, it is equally important that consumers understand what a transfer does — and what it does not do.

A transfer does not end debt review.
A transfer does not remove the debt review status from the credit bureaus.
A transfer does not cancel a court order.
A transfer does not settle any debt.
A transfer does not restart the statutory 60-business-day period under section 86(10) of the NCA.
A transfer does not automatically qualify a consumer for a clearance certificate.

The debt review process continues from the point where it currently stands.

Why consumer education matters

DCASA believes that consumer education must be at the heart of the transfer process.

Many consumers do not always understand the difference between a transfer, a withdrawal, a clearance certificate, or so-called “debt review removal”. This distinction is important because the legal consequences are very different.

Where a consumer has already been declared over-indebted, or where a debt restructuring court order has been granted, the consumer generally remains under debt review until the requirements for lawful clearance have been met. Section 71 of the National Credit Act remains central to this process. A Form 19 clearance certificate can only be issued once the consumer qualifies in terms of the Act and the applicable requirements have been satisfied.

This is why DCASA has submitted a proposed consumer transfer acknowledgement document to the NCR. The purpose of this document is not to restrict a consumer’s right to transfer. The purpose is to ensure that the consumer gives informed instruction and understands that a transfer is not the same as removal, cancellation or clearance.

DCASA’s proposed approach

DCASA’s submission proposes that consumers should acknowledge, in writing, that they understand the nature and consequences of the transfer.

The proposed acknowledgement covers key points such as:

the consumer’s instruction to transfer the matter;

confirmation that the transfer is voluntary;

confirmation that no one has promised unlawful debt review removal or clearance;

confirmation that any existing court order remains valid unless lawfully dealt with;

acknowledgement that the consumer’s Debt Help System status must be verified;

authorisation for the new debt counsellor to obtain the necessary documents and history; and

confirmation that the transfer does not, by itself, settle debts or remove the consumer from debt review.

In DCASA’s view, this kind of document supports both consumer protection and practical implementation. It creates a clearer record for the consumer, the outgoing debt counsellor, the receiving debt counsellor and, where necessary, the NCR.

Practical realities for debt counsellors

Debt review is already an administratively intensive process. A single file may include Form 16, Form 17.1, Form 17.2, certificates of balance, proposals, acceptances, court applications, court orders, PDA payment history, paid-up letters, balance updates, credit provider correspondence and bureau-related documents.

When a file transfers, the receiving debt counsellor must understand exactly where the matter stands. Is the matter still under assessment? Has the consumer been found over-indebted? Has the court process started? Has a court order been granted? Have there been missed payments? Are there paid-up accounts? Are there outstanding documents? Are there unpaid fees for work already completed?

These questions matter because the receiving debt counsellor must continue the process lawfully and accurately.

DCASA therefore supports a standardised and practical transfer pack that assists all parties. The goal should not be to create unnecessary red tape, but rather to ensure that transfers are handled efficiently, consistently and in a way that reduces future disputes.

Fees, proof of work and fairness

The NCR Guideline confirms that a transfer may only be delayed on limited grounds, including outstanding prescribed documentation or outstanding fees due and payable to the existing debt counsellor.

DCASA supports fairness in this regard. Consumers should not be charged again for work already completed and paid for. At the same time, where a debt counsellor has performed work and fees are lawfully due, the debt counsellor should be able to provide a detailed invoice and proof of work.

This protects the consumer from unreasonable charges and protects debt counsellors who have performed legitimate professional work.

Protecting the integrity of debt review

Debt review plays a vital role in South Africa’s credit market. It provides a structured, lawful and regulated mechanism for over-indebted consumers to repay their debts in a sustainable manner.

For that reason, transfers must be handled carefully. A consumer should never be misled into believing that a transfer is a shortcut out of debt review. Equally, a consumer should never be unfairly prevented from transferring to another registered debt counsellor.

The balance lies in clear process, proper records, consumer education and professional cooperation.

DCASA’s call to members and stakeholders

DCASA encourages members to comply with the NCR Guideline and to process valid transfer requests within the prescribed timeframes.

Members are also encouraged to keep proper records, communicate clearly, provide the required documents, and assist consumers with accurate information about their rights and obligations.

We further encourage receiving debt counsellors to ensure that consumers are properly informed before accepting a transferred matter, especially where the consumer may believe that the transfer will result in debt review removal, cancellation of a court order or immediate clearance.

DCASA remains committed to constructive engagement with the NCR, credit providers, PDAs, credit bureaus and other stakeholders to ensure that the transfer process is both consumer-centred and operationally workable.

Conclusion

The NCR Transfer Guideline 004/2026 is a valuable opportunity for the industry to improve consistency, transparency and consumer understanding.

DCASA supports the consumer’s right to transfer. We also believe that this right is best protected when consumers are properly informed and when the industry follows a process that is clear, fair and practical.

As the largest and oldest association representing debt counsellors in South Africa, DCASA will continue to play an active role in supporting a debt review environment that is ethical, sustainable, legally compliant and focused on the long-term rehabilitation of consumers.