Answers for your Board, CFO, HR Director, and payroll team.

No. The Social Ex Gratia Payment is not remuneration and does not form part of any employee's salary or contract of employment. It is made ex gratia — voluntarily, without legal obligation — at the direction of CDII. No employee acquires any right or entitlement from the payment.

No, provided the programme architecture is correctly implemented. The payment arrives on a different date from salary, with a different bank reference, and is described on the payslip as "Social Ex Gratia Payment — non-contractual, non-recurring". The Employee Acceptance Form expressly records the employee's acknowledgement that no expectation is created. The programme also has defined sunset triggers that end it automatically. This mirrors the legal treatment of 13th cheque payments, which courts consistently recognise as non-recurring if properly documented.

No — it is not tax-free. PAYE Code 3601 (Gross Remuneration — ex gratia) applies. PAYE is withheld at the employee's marginal rate.

IRP5 Code 3601 and monthly EMP201 compliance are both required.

The separate pay-run is the most important structural protection against both SARS recharacterisation and employee expectation. A payment that arrives on the same date as salary, via the same payroll cycle, is functionally indistinguishable from salary. Processing it separately — on a different date, with a different bank reference — creates a visible, documented separation that courts, SARS, and trade unions recognise as meaningful. This is exactly how 13th cheque and merit bonus payments are handled. The incremental payroll cost is the price of the structural protection.

At a 27-employee scale, R500 per employee (Tier 3 ceiling), 3 months (total gross R40,500):

• Internal payroll administration time (2–3 hours per month): R1,500–R3,150
• Payroll system cost for the additional run: approximately R810
• Total incremental cost: R2,310–R3,960 over 3 months

UIF and SDL do not apply to the Social Ex Gratia Payment — see Q15. These costs are the employer's responsibility and are not included in the CDII administration fee (7.5% of gross disbursements).

CDII is a B-BBEE Level 1 NPC. The employer's contribution qualifies as Socio-Economic Development (SED) spend under Statement 500 (Generic Scorecard) or Statement 605 (QSE Scorecard), generating up to 5 SED scorecard points. CDII provides a B-BBEE SED confirmation letter for each month of the programme. B-BBEE SED recognition is unconditional — it applies regardless of which tax route (s11(a) or s18A) the employer elects.

Primary route — s11(a) Staff Welfare Expenditure: the company's contribution is deductible as staff welfare expenditure under section 11(a) of the Income Tax Act — immediately, unconditionally, and without a separate SARS election or approval.

Alternatively, employers may elect to claim the contribution as a donation to CDII under section 18A, in which case CDII will issue a Section 18A Certificate.

Donations Tax does not apply. Section 56(1)(h) of the Income Tax Act expressly exempts donations to approved PBOs from Donations Tax. CDII's PBO status (PBO 930 041 456) means no Donations Tax arises on contributions to the SmartCommute™ Commuter Resilience Fund.

Three documents are required before the first payment:

• A signed Board Resolution authorising programme participation (7 substantive resolutions — CDII provides the template)
• A signed Programme Participation Agreement (PPA v5.7 FINAL) with CDII
• A signed Employee Acceptance Form (EAF v6.5) from each Qualifying Employee

Each month CDII provides: a Disbursement Notice; a Section 18A Certificate (if s18A elected); and a B-BBEE SED confirmation letter. These serve as supporting evidence for audit and verification purposes.

The programme ends automatically on whichever of the following two sunset triggers occurs first:

• Trigger A — 30 September 2026: automatic end of the 3-month programme period.
• Trigger B — Essential Services Travel Permits: proclamation or enforcement of Essential Services Travel Permits or fuel rationing measures by a competent government authority.

These are the only two sunset triggers. There is no petrol price trigger. The Participating Employer has no discretion to extend the programme beyond a sunset trigger.

The programme has a fixed 3-month term with no automatic renewal. However, at the Participating Employer's discretion, the term may be extended by one, two, or three months, or renewed for a further fixed 3-month term. See PPA Schedule 1 for the mechanism and process. This discretion does not apply once a sunset trigger under Q10 has fired.

Yes. Participation qualifies as a Social Pillar ESG activity under King V governance principles. Participating Employers are encouraged to report in annual reports, integrated reports, sustainability reports, and investor ESG disclosures.

CDII and the SmartCommute™ logo may be mentioned in company reports describing programme participation. CDII will provide a participation confirmation letter and co-branding authorisation on request.

Yes — under paragraph 11 of the Fourth Schedule to the Income Tax Act, an employee may apply directly to SARS for a directive reducing or eliminating PAYE withheld on a specific payment, on grounds of hardship, using the IRP3(c) form.

• The directive is discretionary — SARS is not obliged to grant it.
• Employees below the R99,000 annual tax threshold already receive nil PAYE — the IRP3(c) is not relevant for them.
• Once a valid directive is issued, the employer must apply the directed rate and has no discretion to override it.

Yes — via a two-track eligibility model:

• Track 1 — Employer Payroll (Code 3601): permanent employees; employed learners registered under section 17 of the Skills Development Act; employed interns on fixed-term contracts. All processed through employer payroll under Code 3601.
• Track 2 — CDII Direct Disbursement: unemployed learners in registered learnerships; stipend-only interns without employment contracts. CDII disburses directly — no employer payroll involvement required.

In both tracks, the standard exclusion applies: the participant must not hold a travel allowance, car allowance, fuel card, or company vehicle.

No. UIF, SDL and COIDA do not apply — each is excluded by statute or ministerial notice:

• UIF (UI Contributions Act 4 of 2002) — does not apply. The payment is not "remuneration in respect of services rendered" as defined.
• SDL (Skills Development Levies Act 9 of 1999) — does not apply. Falls outside the Fourth Schedule remuneration definition.
• COIDA — does not apply. Expressly excluded by the Minister's Notice (April 2025) — voluntary ex gratia payments without legal obligation fall outside the COIDA assessment base.