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Where the B-BBEE Ownership Rules Come From

Every Act, Code of Good Practice, gazetted notice, regulation and court judgment behind this hub — with a link to each, so you can check anything for yourself.

Published Last reviewed 6 min read

Written by

Martin Kotze

Attorney, Conveyancer & Notary Public

Quick answer

Why there are references everywhere

If someone tells you something about B-BBEE ownership, you are entitled to ask where it comes from. Every guide in this hub states a point in plain language and then backs it with the actual source — and this page brings all of those sources together in one place. They are public documents, and you are entitled to read them.

A note on the links: court judgments sit on SAFLII and legislation on the Law Library of South Africa; a couple of these open in a normal browser but block automated tools, so open them in your browser if a link does not resolve first time. The Codes and the gazetted notices are published by the dtic and the B-BBEE Commission.

The sources

Legislation

The Acts of Parliament behind the scorecard, the fronting offence and the funding structures.

Regulators & official templates

The B-BBEE Commission and the dtic — guidance, advisory opinions and the official EME affidavit.

What we could not establish

In the interests of not overstating anything, these are the points where the guide behind this hub was unable to reach a firm answer — and says so in the text:

  • The 25% target used in the second of the two net-value formulas. The scorecard prints “Refer to Annexe C”; verification agencies apply 25% in practice. See net value explained.
  • Whether the 51% rule can be applied where the vehicle in the chain is a trust rather than a company. The wording refers to a “company”, and no official guidance was found either way.
  • The cross-reference to Annexe 100(B) and 100(C) in paragraph 3.9.1, which omits the word “respectively” that equivalent paragraphs contain — an interpretation, not a settled position.
  • The exact text of the Ministerial notice fixing the value threshold for a “major B-BBEE transaction” (generally cited as R25 million). Confirm it before relying on the figure.
  • How the notional balance in a notional vendor finance structure is treated when net value is calculated. No official guidance was found — confirm with your verification agency.
  • How the Annexe 100(B) criteria are applied in practice to a non-profit company.
  • Whether any of the draft amendments published for comment in January 2026 has since been finalised and gazetted. None had been found as at 25 July 2026.

Where a great deal turns on one of these, take independent B-BBEE technical advice, and consider asking the B-BBEE Commission for a non-binding opinion on full disclosure of the facts — remembering that a non-binding opinion creates no safe harbour. Back to the hub, or book a consultation.

For the businesses we act for

The Keystone Workspace

The attorney-designed platform the businesses we act for use to run their contracts, e-signatures and company secretarial work in one place.

Why you can trust this: Martin Kotze has been an admitted Attorney of the High Court of South Africa, registered Conveyancer, and Notary Public since 2014, practising from Pretoria. The firm is regulated by the Legal Practice Council under firm registration 17444.

This guide is general information, not legal advice for your specific matter.

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Structure black ownership that scores — and stays clear of fronting

Martin Kotze structures B-BBEE ownership deals end-to-end — the share sale or scheme, the funding, the trust or company, and the shareholders’ agreement. General guidance on this page is not a substitute for advice on your facts.