SARB's Draft Crypto Asset Manual: What Could Change

National Treasury and the South African Reserve Bank have published a draft Crypto Asset Manual for public comment, open until 30 September 2026. It sits underneath the draft Capital Flow Management Regulations, 2026, and defines when a crypto transaction becomes "cross-border" under South African exchange control, and what happens once it does.

The trigger point is any movement of crypto assets between a domestic Authorised Crypto Asset Service Provider (CASP) and either an offshore CASP or a non-custodial wallet. Once that line is crossed, the transaction becomes reportable to the Financial Surveillance Department (FinSurv), SARB's unit responsible for detecting and disrupting illicit financial flows.

SARB’s stated goal is to close the gap where crypto rails have offered a route to move value across borders without the reporting that fiat cross-border flows require. This is the existing exchange control logic, extended to crypto rails.

What it means for current CASPs

Most crypto businesses operating in South Africa are licensed as Financial Services Providers under the FSCA's existing crypto asset framework.

If approved, the draft regulations would mean that holding Authorised CASP status would only enable part of what CASPs may currently be doing: processing cross-border crypto movement for individuals acting within their Single Discretionary Allowance or Foreign Capital Allowance; the same limits that apply to fiat.

The biggest proposed change prevents CASPs from facilitating cross-border crypto transfers for business or corporate clients. Entity-level cross-border crypto movement is excluded outright, regardless of licensing

What it means for businesses using crypto rails to move money cross-border

• Only individuals will be permitted to externalise crypto assets, and only within their existing Single Discretionary Allowance or Foreign Capital Allowance
• For any South African entity, moving crypto assets to an offshore CASP or a non-custodial wallet is classified as non-permissible
• If a business has used crypto as a cross-border settlement mechanism, that route is closed under the current draft.

Most important to note, is that this is still a draft. The comment window is open until 30 September 2026, with submissions going to [email protected] in the format set out in Annexure A.

Treasury and SARB have also said this Manual hasn't yet absorbed feedback already submitted on the underlying Regulations, so the final version may change.

So, take action. Anyone who may be affected by these changes, like CASPs or businesses using crypto rails, should read Table 1 in the draft Manual against their flows before the window closes, and submit comments while it's still open to shape.