BitcoinZAR Advocacy Group
Unified voice for Bitcoin in South Africa
Professional, coordinated public comments on regulations that affect Bitcoiners.
Broadcast-only • No chat • Deadline: 30 September 2026
Active Campaign
Draft Crypto Assets Manual for cross-border activities
The draft Crypto Assets Manual for cross-border activities, published jointly by National Treasury and the South African Reserve Bank on 3 August 2026, sets out how the draft Capital Flow Management Regulations 2026 (which are fundamentally flawed and has not been finalised) would be applied to crypto. It defines when a crypto move counts as a cross-border flow (mainly when assets leave a domestic Authorised Crypto Asset Service Provider for an offshore CASP or a non-custodial wallet, or the reverse), makes those flows reportable to the Financial Surveillance Department, and limits outbound externalisation at this stage to individuals using their single discretionary or foreign capital allowances via Authorised CASPs. It also covers the process to become an Authorised CASP, permissions and conditions on cross-border crypto activity, and related admin and reporting duties, while treating purely domestic buys, sells, and transfers between local Authorised CASPs as non-reportable. Comments close 30 September 2026.
Community Impact So Far
Summary of Concerns
- Publishing a detailed Draft Crypto Asset Manual while the underlying Capital Flow Management Regulations remain unfinished is a clear waste of taxpayer money.
- Officials are forcing the public and industry to engage with secondary rules whose legal foundation can still change substantially.
- No public response has been given to earlier comments on the primary draft Regulations, yet resources continue to be spent developing and consulting on the Manual.
- This parallel drafting process undermines meaningful consultation and legal certainty.
- It raises serious concerns under the principles of legality and rationality, as subordinate instruments must remain within the limits of their empowering statute.
- Taxpayers should not fund premature and potentially redundant regulatory work.
We suggest sending your email to the following recipients, our template will preload them but you are free to modify/edit as you see fit:
Primary (official comments address):
Strongly recommended to copy:
- [email protected]
- [email protected]
- [email protected] (Ministry of Finance / Minister’s office)
- [email protected] (Director-General’s registry)
Optional additional contacts:
- [email protected] (Personal Assistant to the Minister of Finance)
Supported By:
If you are a Bitcoin Company and your LOGO isn’t here, it means you either don’t support this or you haven’t told us…get in touch
Submit Your Comment – Takes Under 60 Seconds
Fill in your details and we’ll generate the text for you to either manually copy and paste into an email that includes your personalised story, or generate the email in your own client (requires JavaScript and may not work on all devices).
We DO NOT capture or store any information you enter here, it simply opens your email client and pre fills the message ready for you to edit or simply send directly to the regulator. Please untick the counter box if you do not which to anonymously count your submission in our counter (we hope you don’t).
All submissions are sent directly to National Treasury by YOU. The button opens your mail client with all the detail completed and allows you to modify or just hit send. Alternatively you can hit Generate and copy and paste it yourself.
We only count submissions where users opt-in to the public counter.
Why This Campaign Matters
The TL;DR
A self-custody wallet is effectively treated as “offshore”.
Sending crypto from a local CASP to your own hardware wallet is classified as an export of capital, even though ownership has not changed and a non-custodial wallet has no objective geographical location. This is the biggest conceptual departure from CEMAD, which normally looks at residency, counterparty and economic purpose.
Self-custody is asymmetrical.
Outward transfers to a non-custodial wallet are permitted under the SDA/FCA, but transferring crypto back from a non-custodial wallet to a South African CASP is expressly non-permissible. Repatriation must apparently originate from an offshore custodial CASP. This could force customers to route self-custodied assets through a foreign exchange merely to return them to South Africa.
South African companies are entirely excluded from cross-border crypto.
Resident entities may trade locally but cannot make any crypto transaction classified as an import or export of capital. That is far more restrictive than CEMAD, under which companies can conduct numerous approved foreign investments, imports, exports, loans and other cross-border transactions.
CMA residents are apparently prohibited from using Authorised CASPs at all.
The Manual says CASPs may not transact with residents of Lesotho, Namibia or eSwatini, and the tables classify even their domestic purchases and sales as non-permissible. This is difficult to reconcile with the generally integrated treatment of Rand transactions within the Common Monetary Area.
Authorised CASP licensing requirements.
An Authorised CASP must hold ring-fenced unimpaired capital equal to the higher of R5 million or 15% of average positive gross income, which cannot be withdrawn without FinSurv approval. FinSurv must also approve changes to directors, beneficial ownership, business models, premises and even the launching or closing of an electronic platform.
Private CASPs are encouraged to use search powers.
The Manual says CASPs may call for information and search premises to inspect books or documents, and should “fully avail” themselves of those powers. Delegating intrusive enforcement powers to private crypto businesses is highly unusual and does not have an obvious CEMAD equivalent.
About the BitcoinZAR Advocacy Group
The BitcoinZAR Advocacy Group was started in April 2026 by three passionate South African Bitcoiners who saw the need for a coordinated, professional community response to important Bitcoin-related regulations.
Our mission is simple: To protect and promote sensible, Bitcoin-friendly policies in South Africa by mobilising the local Bitcoin community to submit high-quality, constructive public comments on draft laws and regulations.
This platform provides easy tools, unified templates, and clear calls to action so every Bitcoiner can participate effectively.
How You Can Help?
A single unified voice is much stronger than many scattered comments. Here’s how you can make a real difference today:
Submit Your Comment
Use our simple template above. It takes less than 60 seconds and goes straight to National Treasury.
Share With the Community
Spread the campaign on X, WhatsApp, Telegram groups, and local Bitcoin communities. Every share helps.
Help Spread the Banner
If you run a Bitcoin-related website on WordPress, install our free banner plugin (coming soon) to show the active campaign to your visitors.