Self-assessment
B-BBEE Property Sector Code Self-Assessment
14 yes/no questions on the B-BBEE Property Sector Code: whether it applies to you, your size category, proof of your level, the scorecard elements, and the requirements specific to the sector. You get a score for each area and a list of gaps with what to do about each one.
1. Does the sector code apply, and where do you fit?
The amended B-BBEE Property Sector Code was issued on 9 June 2017 and replaced the 2012 code. Reports say the 2017 code raised the bar: entities must score at least 40 points to be B-BBEE compliant, compared with 30 points under the 2012 code.
1. Have you checked that your business falls inside the scope of the Property Sector Code, and recorded the answer?
(B-BBEE Act s9, sector code scope)
2. Do you know your size category (exempted micro enterprise, qualifying small enterprise or generic enterprise) under this sector code?
Sources conflict. An older slide deck gave asset-based property businesses an EME test of net assets under R30 million, and another source gave estate agents, brokers and valuers a turnover cut-off of R2.5 million. Check the gazetted 2017 code for the thresholds that apply to you. (Sector code, size thresholds)
3. Do you hold the right proof of your level, either a verification certificate from an accredited agency or, where this sector code allows it, a sworn affidavit?
(Sector code, verification)
2. The scorecard elements
Answer Not applicable for any element your size category is not measured on.
1. Do you know the black ownership of your business and can you prove it from your share register and agreements?
(Sector code, Ownership)
2. Do you track black people and black women at board, executive and management levels against the sector code's targets?
(Sector code, Management Control)
3. Do you spend on skills development for black people, and keep proof of the spend and the training?
(Sector code, Skills Development)
4. Do you buy from, and develop, black-owned and small suppliers, and track the spend and the support you give?
(Sector code, Enterprise and Supplier Development)
5. Do you make socio-economic contributions that benefit black people and keep proof?
(Sector code, Socio-Economic Development)
3. Property sector requirements
These are the items the sources describe for this sector. Check the gazetted code for the full list of elements and targets.
1. Do you know whether you are an asset-based business (such as an owner or developer) or a service business (such as an agent, broker or valuer), since the code treats them differently?
(Amended Property Sector Code)
2. Do you know the minimum points you must score under the 2017 code to be treated as B-BBEE compliant (reported as 40), and your current score?
(Amended Property Sector Code)
3. Do you track ownership and the sector's land and property transformation elements, such as black ownership of property and property transactions with black-owned parties, and keep evidence?
(Amended Property Sector Code (ownership and property-specific elements))
4. If you are an estate agent, are you registered with the Estate Agency Affairs Board and do you hold a valid fidelity fund certificate?
(Property Practitioners Act)
5. Do you meet FICA duties as a property practitioner, such as registering with the FIC and reporting suspicious transactions?
(FICA Schedule 1)
4. Evidence and reporting
1. Do you keep one evidence file per element each year, so a verifier or the sector council can check your claims?
(Sector code, verification)
Sources
Turn these gaps into tracked tasks
Assign owners and due dates, keep the evidence, and show your progress to clients and auditors.