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. Each employer’s participation also has a defined end: its fixed 3-month term ends automatically unless renewed in writing, and CDII may end it earlier by written notice (see Q10). 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, R600 per employee (Band A), 3 months (total gross R48,600):

• 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 answer depends on how you contribute:

• Participation for your own employees (the usual SmartCommute™ route): this does not earn Socio-Economic Development (SED) points. The B-BBEE Codes do not recognise contributions whose beneficiaries are the measured entity's own employees.
• An unrestricted contribution to the Fund's pool, which you do not direct to your own employees and for which CDII alone selects the beneficiaries: this may qualify as SED spend under Statement 500 (Generic Scorecard) or Statement 605 (QSE Scorecard), provided at least 75% of its value benefits black people and it supports income-generating activity. Where it qualifies, CDII provides an SED Verification Letter.

Your B-BBEE Verification Agency decides what it recognises. Please confirm with them before relying on SED points.

• Participation for your own employees: the contribution is generally deductible as staff welfare expenditure under section 11(a) of the Income Tax Act, subject to the usual requirements (it must be incurred in carrying on your trade, in the production of income, and not be of a capital nature). Because it benefits your own employees, it is not a donation, so section 18A does not apply.
• Unrestricted contribution to the Fund's pool: this may qualify as a donation under section 18A, and CDII will then issue a Section 18A Certificate, provided it is a bona fide donation with no benefit to you or anyone connected to you, and within the limit of 10% of your taxable income.

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 & Master Agreement (PP&MA v1.1) with CDII
• A signed Employee Acceptance Form (EAF v6.6) from each Qualifying Employee

Each month CDII provides a Disbursement Notice. For unrestricted pooled contributions only, CDII also provides either a Section 18A Certificate or an SED Verification Letter, as elected on the Benefit Election Form (Document N).

The programme is continuously available. Each Participating Employer's participation is a fixed 3-month term from its own start date, which ends on whichever of the following occurs first:

• Close of the 3-month term: automatic end unless renewed in writing at the Participating Employer's discretion.
• CDII determination of material change: written notice from CDII, acting as Programme Administrator, following its determination — based on evidence presented to it — of a material macroeconomic development or a material company-specific event substantiating that the circumstances for the programme have materially changed.

There is no petrol price trigger.

Yes — at the Participating Employer's discretion, the term may be extended or renewed by one, two, or three months, or for a further 3-month term, in writing under PP&MA Schedule 1. This discretion does not apply once CDII has issued a material-change notice.

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 hosted by a Participating Employer; stipend-only interns without employment contracts. CDII disburses directly — no employer payroll involvement required.

Contact CDII to discuss Track 2 participation.

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.