A registration total tells institutions how many businesses have entered the system. It does not tell them how many are ready to trade lawfully. For municipalities, Environmental Health Practitioners (EHPs) and corporate partners preparing for year-end, that distinction should drive the conversation: which requirements remain outstanding, who is responsible for the next step, and what support can help businesses move forward without confusing preparation with approval?
Registration is not the same as compliance
The national registration drive closed on 28 February 2025, and government said work by multi-disciplinary teams would continue beyond the deadline. Registration, however, is an administrative step. Food-safety compliance is a separate, regulated question.
Under the Regulations Governing General Hygiene Requirements for Food Premises (R638 of 2018), premises must obtain a Certificate of Acceptability from the local authority, and food may not be handled on premises without a valid certificate. The certificate must be displayed and is not transferable, and the person in charge must ensure that everyone working on the premises is suitably trained in food safety and hygiene. Mogale City drew the same line in its media statement: registration alone does not mean a business is eligible to trade, because it must also comply with health regulations and municipal by-laws.
The gap shows in the numbers. Mogale City reports receiving 617 applications from spaza shop owners, of which its compliance assessment found only five fully complied with all applicable requirements (the page is undated). Nationally, CoGTA figures reported after a Parliamentary committee briefing in March 2026 put registered spaza shops at 81,039, of which 18,722 were licensed or permitted to operate. These figures measure different things and should not be compared directly, but they point the same way: registration counts overstate readiness.
Why the gap persists
Documentation. Mogale City’s published application list includes certified identity or permit documents, CIPC and SARS registration, a bank account record, proof of residence, a Certificate of Acceptability and a fire compliance certificate, the last two listed as issued by the West Rand District Municipality (Mogale City). The Department of Small Business Development has told Parliament that a missing Certificate of Acceptability, trading permit or licence is the main reason Spaza Shop Support Fund applications are incomplete. The operational implication is important: where documents and approvals involve different offices, businesses need clarity on both the requirements and the sequence in which to complete them.
Capacity. Food control is part of municipal health services under the National Health Act. On 17 July 2026 the Public Protector issued a preliminary Section 7(9) notice on Gauteng food-safety enforcement. As reported, it pointed to widespread Environmental Health Practitioner capacity constraints across Gauteng municipalities, and every Gauteng municipality fell short of the benchmark of one EHP per 10,000 people as of October 2025. This is a preliminary notice, not a final report, and it could not be confirmed whether a final report has been issued.
Coordination and verification. Parliament’s Portfolio Committee on Small Business Development described the municipal licensing backlog as the primary constraint on the Spaza Shop Support Programme, and the Department has asked municipalities to verify the authenticity of permits and share lists of approved permits, licences and certificates. A useful implementation process must therefore make two things visible: which documents are outstanding and which completed documents still require verification.
Who is responsible for what
- Municipalities carry the decisions: licensing, zoning and municipal health services including food control. The local authority issues the Certificate of Acceptability.
- Environmental Health Practitioners assess premises against R638 and related norms. In Mogale City’s published list the certificate and fire documents are attributed to the West Rand District Municipality, so partners should confirm the current arrangement before directing applicants.
- Business owners and persons in charge carry the legal duties on the premises, including display of the certificate and staff training.
- Implementation partners have no statutory role. Their useful contribution is information, document preparation, appointment coordination, follow-up and transparent reporting.
Clear role boundaries are part of credible delivery. Every partner communication should distinguish assistance from authorisation, so that a completed checklist, an outreach visit or programme participation is never mistaken for permission to trade.
Practical responses before the festive period
- Track each business by stage, not by registration. Define stages such as information given, documents complete, submitted, awaiting Environmental Health, awaiting certificate and awaiting licence, and agree the definitions with the municipality.
- Check documents early and specifically. A short, municipality-approved checklist for certified copies and supporting records should reduce repeat visits. This is a hypothesis to test, not an established result.
- Use one short set of food-safety messages. The WHO’s Five Keys to Safer Food (keep clean, separate raw and cooked, cook thoroughly, keep food at safe temperatures, use safe water and raw materials) give partners a shared vocabulary. Awareness supports, but does not replace, the requirements of R638.
- Plan for the holiday slowdown. In December 2024 government said that despite the holiday scaling down of operations, municipalities must still reserve capacity to assist applicants. Agree reduced-hours contact arrangements before mid-December.
- Name a municipal contact for queries, so partners are not guessing at requirements.
Monitoring implementation without presenting activity as proof of impact
Credible reporting separates effort, progress and outcomes. Partners can report sessions held, checklists issued and businesses contacted. Progress through application stages should be confirmed against municipal records. Certificates and licences are regulatory decisions; changes in food-handling practice require appropriate observation and evidence. Each reported measure should include its denominator, reporting period and data source. Verified outcomes can be reported as such, but their existence does not establish that partner support caused them. Where evidence is incomplete or samples are small, say so.
Where #SpazaConnect© fits
#SpazaConnect© is a platform piloted in Mogale City that supports informal food businesses with registration and food-safety readiness, including a published how-to registration guide. Its contribution is practical: helping businesses understand the process, prepare documentation and identify the next step. It is not a regulator, an Environmental Health Practitioner or a municipal authority. It does not conduct statutory inspections, issue Certificates of Acceptability, determine regulatory compliance or guarantee approval. The distinction defines a focused implementation role: support preparation while leaving assessment and authorisation with the responsible authorities.
What institutional partners could consider at year-end
- Do our counts separate applications received from stages completed?
- Where do files stall, and for how long?
- What would reduce repeat visits for municipal staff, and can partners provide it without duplicating statutory work?
- How would reform change the work? The Department of Small Business Development published a draft Business Licensing Bill in May 2026, with comments closing on 2 June 2026. Its introduction to Parliament has not been confirmed in this plan, so it should be treated as a proposal rather than an enacted requirement.
- Which 2027 activities are firm commitments and which are only items for discussion?
The year-end priority is not another registration headline. It is a clearer account of what happens next: which businesses have outstanding requirements, where applications are waiting and who owns the follow-up. Municipalities retain the decisions. Partners can support preparation and make progress visible without presenting activity as impact or assistance as approval. That is the basis for a more credible year-end review—and a more focused discussion about support in 2027.
If your municipality or corporate programme is considering practical support for spaza shop formalisation and township business growth, speak to Siyakha Consulting and #SpazaConnect© about the outstanding requirements in your area and where partnership support could fit. Contact tumelo.dichabe@siyakha.co.za. Businesses seeking registration guidance can visit spazaconnect.co.za.
