𝐂𝐨𝐦𝐩𝐞𝐭𝐞𝐧𝐜𝐲–𝐁𝐚𝐬𝐞𝐝 𝐏𝐚𝐭𝐡𝐰𝐚𝐲: 𝐓𝐡𝐞 𝐑𝐞𝐚𝐥 𝐄𝐬𝐭𝐚𝐭𝐞 𝐈𝐧𝐝𝐮𝐬𝐭𝐫𝐲 𝐃𝐞𝐬𝐞𝐫𝐯𝐞𝐬 𝐀𝐧𝐬𝐰𝐞𝐫𝐬, 𝐓𝐫𝐚𝐧𝐬𝐩𝐚𝐫𝐞𝐧𝐜𝐲 𝐚𝐧𝐝 𝐄𝐪𝐮𝐚𝐥 𝐎𝐩𝐩𝐨𝐫𝐭𝐮𝐧𝐢𝐭𝐲
The introduction of the PPRA’s alternative competency-based pathway from 1 August 2026 has generated significant debate within the South African real estate industry. While some industry bodies have publicly supported the initiative, it is important that the impression is not created that the entire industry is united behind it.
There are training providers, associations, practitioners and other stakeholders who have raised concerns and who believe that fundamental questions remain unanswered.
The discussion should therefore not become a contest between those who support the pathway and those who oppose it. The facts must be evaluated, the unanswered questions must be addressed, and the industry deserves transparency about how this new system will operate.
𝐍𝐨𝐭 𝐄𝐯𝐞𝐫𝐲𝐨𝐧𝐞 𝐀𝐠𝐫𝐞𝐞𝐬
During the REBOSA webinar, it was stated that REBOSA and members of the National Property Practitioners Council supported the competency-based approach and that “virtually everybody in the industry supports this”.
However, the same meeting acknowledged that a number of training institutions had come out against the concept. The indicated criticism from training providers concerned about moving away from the qualification system that had developed since mandatory qualifications were introduced.
𝐓𝐡𝐚𝐭 𝐝𝐢𝐬𝐭𝐢𝐧𝐜𝐭𝐢𝐨𝐧 𝐢𝐬 𝐢𝐦𝐩𝐨𝐫𝐭𝐚𝐧𝐭.
The existence of support from major representative bodies should not be interpreted as evidence of unanimous industry support. Organisations and stakeholders that have raised objections deserve to have their submissions evaluated on their merits by the PPRA too.
The PPRA itself states that the new route is an additional pathway, rather than a replacement for the existing NQF Level 4 qualification routes. Under the new pathway, a candidate with Matric may pass the PPRA examination and complete six prescribed practical training modules without first obtaining the NQF Level 4 Real Estate qualification. Candidates following this route will, however, not qualify for the PPRE professional designation unless they obtain the prescribed qualification.
That alone demonstrates why a broader professional discussion is necessary.
𝐖𝐞 𝐌𝐮𝐬𝐭 𝐀𝐥𝐬𝐨 𝐑𝐞𝐦𝐞𝐦𝐛𝐞𝐫 𝐇𝐨𝐰 𝐖𝐞 𝐀𝐫𝐫𝐢𝐯𝐞𝐝 𝐇𝐞𝐫𝐞
The present backlog of candidates did not develop overnight.
For years, estate agents were warned about education requirements. In fact, Practice Note ETD01/2020 provided deadlines for affected practitioners to complete the NQF Level 4 qualification and PDE requirements and warned that failure to comply could result in disqualification.
𝐓𝐡𝐞 𝐢𝐧𝐝𝐮𝐬𝐭𝐫𝐲 𝐭𝐡𝐞𝐫𝐞𝐟𝐨𝐫𝐞 𝐧𝐞𝐞𝐝𝐬 𝐭𝐨 𝐚𝐬𝐤 𝐚𝐧 𝐮𝐧𝐜𝐨𝐦𝐟𝐨𝐫𝐭𝐚𝐛𝐥𝐞 𝐪𝐮𝐞𝐬𝐭𝐢𝐨𝐧:
Did the qualification system fail, or did the industry fail to enforce and comply with the qualification system consistently?
The REBOSA itself acknowledges that candidates were allowed to remain candidates for extended periods and records figures presented during the meeting suggesting that only a relatively small percentage completed NQF4.
If candidates ignored qualification deadlines for years, replacing the consequence with an easier or faster alternative could create an unintended message: those who invested substantial time and money in recognised qualifications carried the burden, while those who delayed may ultimately receive a shorter route.
That perception needs to be addressed.
𝐓𝐡𝐞 𝐏𝐫𝐚𝐜𝐭𝐢𝐜𝐚𝐥 𝐓𝐫𝐚𝐢𝐧𝐢𝐧𝐠 𝐐𝐮𝐞𝐬𝐭𝐢𝐨𝐧𝐬 𝐑𝐞𝐦𝐚𝐢𝐧 𝐔𝐧𝐚𝐧𝐬𝐰𝐞𝐫𝐞𝐝
Perhaps the most important admission in the REBOSA discussion was that substantial detail about the new pathway was still outstanding.
Questions were specifically raised about whether candidates would complete the practical modules before or after the PPRA examination and when the new examination would become available.
REBOSA in its own publication confirmed that the six prescribed practical modules (Workplace of OC Real Estate Agent) remain part of the competency pathway and that the current curriculum and practical training requirements remain unchanged “until further notice”?
𝐓𝐡𝐚𝐭 𝐜𝐫𝐞𝐚𝐭𝐞𝐬 𝐬𝐞𝐯𝐞𝐫𝐚𝐥 𝐢𝐦𝐩𝐨𝐫𝐭𝐚𝐧𝐭 𝐪𝐮𝐞𝐬𝐭𝐢𝐨𝐧𝐬:
- Who will develop and control the examination?
- Who will assess the six practical modules?
- What assessment criteria and moderation processes will apply?
- Will these remain aligned with the workplace component currently associated with the Occupational Certificate: Real Estate Agent?
- Who may legitimately deliver the practical training?
- What qualifications must that trainer or mentor possess?
- Who verifies that practical competence has genuinely been achieved?
- What safeguards will prevent a situation in which inadequately trained candidates effectively train other candidates?
These are not questions designed to obstruct transformation or access. They are questions about quality assurance and consumer protection.
𝐍𝐨𝐭 𝐄𝐯𝐞𝐫𝐲𝐨𝐧𝐞 𝐈𝐬 𝐀𝐮𝐭𝐨𝐦𝐚𝐭𝐢𝐜𝐚𝐥𝐥𝐲 𝐚 𝐓𝐫𝐚𝐢𝐧𝐞𝐫
Practical experience is essential in real estate, but experience and the ability to facilitate structured learning are not automatically the same thing.
If practical training is intended to demonstrate competence based syllabus, surely the person supervising or facilitating that learning should have appropriate subject-matter expertise.
At minimum, serious consideration should be given to requiring appropriate supervision by a properly qualified and experienced principal or other suitably qualified practitioner, together with clearly defined training, assessment and facilitation standards.
Otherwise, the industry risks creating a circular problem: candidates training candidates without adequate educational oversight.
A competency-based system is only as credible as the people who train, assess, moderate and certify that competence.
𝐈𝐬 𝐓𝐡𝐢𝐬 𝐑𝐞𝐚𝐥𝐥𝐲 𝐚𝐧 𝐄𝐪𝐮𝐚𝐥 𝐎𝐩𝐩𝐨𝐫𝐭𝐮𝐧𝐢𝐭𝐲 𝐟𝐨𝐫 𝐓𝐫𝐚𝐢𝐧𝐢𝐧𝐠 𝐏𝐫𝐨𝐯𝐢𝐝𝐞𝐫𝐬?
During the REBOSA webinar, training institutions were encouraged to view the new pathway as a business opportunity by developing courses that could help candidates prepare for the PPRA examination.
In principle, that sounds positive.
But equal opportunity must exist in practice as well as in theory.
The same webinar specifically recommended Charter Academy for CPD, referred to its pricing and module offering, and stated that practitioners could obtain their required CPD points through that provider.
There is nothing inherently improper about recommending a provider. However, where one provider enjoys significant exposure through influential industry structures, other accredited and experienced training providers are entitled to ask how opportunities are allocated.
Rather than alleging favouritism without evidence, the industry should request transparent answers:
𝐖𝐡𝐚𝐭 𝐢𝐬 𝐭𝐡𝐞 𝐏𝐏𝐑𝐀‘𝐬 𝐩𝐫𝐨𝐜𝐞𝐬𝐬 𝐟𝐨𝐫 𝐫𝐞𝐜𝐨𝐠𝐧𝐢𝐬𝐢𝐧𝐠 𝐩𝐫𝐨𝐯𝐢𝐝𝐞𝐫𝐬? 𝐖𝐡𝐚𝐭 𝐜𝐫𝐢𝐭𝐞𝐫𝐢𝐚 𝐚𝐫𝐞 𝐮𝐬𝐞𝐝? 𝐇𝐨𝐰 𝐜𝐚𝐧 𝐨𝐭𝐡𝐞𝐫 𝐜𝐨𝐦𝐩𝐞𝐭𝐞𝐧𝐭 𝐭𝐫𝐚𝐢𝐧𝐢𝐧𝐠 𝐩𝐫𝐨𝐯𝐢𝐝𝐞𝐫𝐬 𝐩𝐚𝐫𝐭𝐢𝐜𝐢𝐩𝐚𝐭𝐞? 𝐀𝐫𝐞 𝐨𝐩𝐩𝐨𝐫𝐭𝐮𝐧𝐢𝐭𝐢𝐞𝐬 𝐚𝐝𝐯𝐞𝐫𝐭𝐢𝐬𝐞𝐝 𝐨𝐩𝐞𝐧𝐥𝐲? 𝐀𝐫𝐞 𝐭𝐡𝐞 𝐬𝐚𝐦𝐞 𝐜𝐫𝐢𝐭𝐞𝐫𝐢𝐚 𝐚𝐩𝐩𝐥𝐢𝐞𝐝 𝐭𝐨 𝐞𝐯𝐞𝐫𝐲𝐛𝐨𝐝𝐲?
Transparency would protect not only training providers, but also the PPRA and industry associations from perceptions of preferential treatment.
𝐏𝐫𝐨𝐩𝐂𝐞𝐫𝐭 𝐑𝐚𝐢𝐬𝐞𝐬 𝐀𝐧𝐨𝐭𝐡𝐞𝐫 𝐈𝐦𝐩𝐨𝐫𝐭𝐚𝐧𝐭 𝐆𝐨𝐯𝐞𝐫𝐧𝐚𝐧𝐜𝐞 𝐐𝐮𝐞𝐬𝐭𝐢𝐨𝐧
The REBOSA webinar also strongly recommended the use of PropCert for FFC applications and renewals. Accordingly, PropCert is operated by an independent company, SwitchX. The stated benefit is that documents and payment records are retained and applications can more easily be followed up with the PPRA.
Importantly, the webinar itself acknowledges that REBOSA and its representatives do not have authority to issue certificates.
The PPRA’s own official FFC portal describes the PPRA platform as the system for registrations, FFC applications, renewals and certificate management.
The question therefore is not necessarily whether PropCert is doing something unlawful. Rather:
𝐖𝐡𝐚𝐭 𝐢𝐬 𝐢𝐭𝐬 𝐩𝐫𝐞𝐜𝐢𝐬𝐞 𝐫𝐞𝐠𝐮𝐥𝐚𝐭𝐨𝐫𝐲 𝐫𝐨𝐥𝐞?
If it is simply an administrative intermediary that securely stores documents and assists applicants in submitting and tracking applications, this should be clearly communicated.
But the industry should understand where the private intermediary’s function ends and where the statutory function of the PPRA begins.
That distinction becomes particularly important when personal information, regulatory documentation and payments are involved.
𝐍𝐂𝐂 𝐎𝐩𝐭–𝐎𝐮𝐭 𝐑𝐞𝐠𝐢𝐬𝐭𝐫𝐲: 𝐖𝐡𝐚𝐭 𝐀𝐛𝐨𝐮𝐭 𝐏𝐎𝐏𝐈𝐀?
The NCC’s new Opt-Out Registry presents another important issue.
The NCC confirms that direct marketers must register and cleanse their marketing lists against consumers who have exercised their right to opt out.
During the REBOSA webinar, the process was described as one where a direct marketer would effectively submit its database to the system, have excluded consumers identified, and then cleanse its database accordingly.
𝐓𝐡𝐢𝐬 𝐢𝐦𝐦𝐞𝐝𝐢𝐚𝐭𝐞𝐥𝐲 𝐫𝐚𝐢𝐬𝐞𝐬 𝐚 𝐥𝐞𝐠𝐢𝐭𝐢𝐦𝐚𝐭𝐞 𝐏𝐎𝐏𝐈𝐀 𝐪𝐮𝐞𝐬𝐭𝐢𝐨𝐧.
A real estate agency’s database may contain names, telephone numbers, email addresses and other personal information. POPIA requires personal information to be processed lawfully, reasonably, for a defined purpose, and subject to principles including minimality.
Consent is not necessarily the only lawful basis for processing personal information, so it would be premature to state that every data subject must necessarily provide fresh consent before information can be processed through a legally mandated registry.
Nevertheless, the question deserves a definitive regulatory answer:
What is the lawful POPIA basis for transmitting database information to the NCC Opt-Out Registry, exactly what information must be transmitted, how will it be secured, how long will it be retained, and what information must agencies provide to their data subjects about this processing?
The industry should not have to guess, we need to find out more information!
𝐂𝐨𝐦𝐩𝐞𝐭𝐞𝐧𝐜𝐲 𝐌𝐮𝐬𝐭 𝐌𝐞𝐚𝐧 𝐌𝐨𝐫𝐞 𝐓𝐡𝐚𝐧 𝐏𝐚𝐬𝐬𝐢𝐧𝐠 𝐚𝐧 𝐄𝐱𝐚𝐦𝐢𝐧𝐚𝐭𝐢𝐨𝐧.
There is merit in examining whether South Africa’s previous education system created unnecessary barriers, delays and administrative problems. Reform should never be rejected merely because it changes an established system.
𝐁𝐮𝐭 𝐫𝐞𝐟𝐨𝐫𝐦 𝐦𝐮𝐬𝐭 𝐚𝐥𝐬𝐨 𝐧𝐨𝐭 𝐬𝐚𝐜𝐫𝐢𝐟𝐢𝐜𝐞 𝐩𝐫𝐨𝐟𝐞𝐬𝐬𝐢𝐨𝐧𝐚𝐥𝐢𝐬𝐚𝐭𝐢𝐨𝐧.
Property practitioners advise consumers on transactions involving homes, investments and substantial amounts of money. They operate within a complex regulatory environment involving the Property Practitioners Act, FICA, POPIA, consumer protection, contracts, mandates, disclosure obligations, trust money and professional ethics.
Passing an examination can test knowledge. It does not automatically prove sustained workplace competence.
That is precisely why the design, supervision, assessment and quality assurance of the practical component are so important.
𝐓𝐡𝐞 𝐈𝐧𝐝𝐮𝐬𝐭𝐫𝐲 𝐍𝐞𝐞𝐝𝐬 𝐚 𝐏𝐮𝐛𝐥𝐢𝐬𝐡𝐞𝐝 𝐈𝐦𝐩𝐥𝐞𝐦𝐞𝐧𝐭𝐚𝐭𝐢𝐨𝐧 𝐅𝐫𝐚𝐦𝐞𝐰𝐨𝐫𝐤
Before the competency-based pathway becomes entrenched, the PPRA should consider publishing a comprehensive implementation framework explaining the examination, curriculum, practical modules, trainer requirements, assessor requirements, moderation, appeals, recognition of training providers, transition arrangements and quality-assurance mechanisms.
The PPRA’s announcement says that the existing practical training requirements remain unchanged until further notice.
“Until further notice” is precisely why stakeholders are asking questions now.
The issue should not be reduced to qualification versus competency.
The real objective should be qualification, competency, ethics, practical ability and consumer protection.
South Africa spent many years moving real estate towards recognition as a profession. Any new pathway should strengthen that progress rather than unintentionally create uncertainty about what it means to be professionally qualified.
The questions being raised by training providers, associations, principals and practitioners should therefore not be dismissed as resistance to change.
𝐓𝐡𝐞𝐲 𝐬𝐡𝐨𝐮𝐥𝐝 𝐛𝐞 𝐚𝐧𝐬𝐰𝐞𝐫𝐞𝐝.
Because when an entire profession is being reshaped, consultation must be broad, opportunities must be equal, standards must be measurable, practical training must be credible, personal information must be protected, and the rules must be transparent to everyone.
Published by ORETSA
www.oretsa.org.za