A procurement team asks for your B-BBEE certificate before it releases a tender pack. Your finance director has a scorecard estimate, but the invoices, learner records and supplier certificates sit across three departments.
That is where a B-BBEE audit becomes urgent. Strictly speaking, B-BBEE verification is not a statutory financial audit. It is an evidence-based process in which a verification agency tests and substantiates the claims behind your scorecard.
For South African enterprises, preparation starts well before the agency requests its first document. We recommend building a controlled evidence file, assigning an owner to each scorecard element and reconciling every claimed amount to accounting records.
Start by confirming the measurement route
Do not begin with a generic B-BBEE scorecard spreadsheet. First establish whether a gazetted sector code applies to your business, because a binding sector code takes precedence over the Generic Codes.
Under the Generic Codes, an Exempted Micro Enterprise, or EME, has annual turnover of R10 million or less. A Qualifying Small Enterprise, or QSE, has turnover above R10 million and up to R50 million. A large enterprise exceeds R50 million.
This classification determines both the route and the depth of preparation. An EME may use a sworn affidavit or CIPC certificate. A QSE that is at least 51% black owned may use a sworn affidavit, while other QSEs and large enterprises require accredited verification.
The judgement call is straightforward. If your business qualifies as an EME, do not pay for a verification certificate merely because a customer asks for “B-BBEE documents”. Confirm the customer’s tender terms, then use the applicable gazetted affidavit template or CIPC route where the rules permit it.
Use the correct affidavit where an affidavit applies
The B-BBEE Commission directs EMEs and qualifying black-owned QSEs to use the applicable gazetted sworn-affidavit template. A Commissioner of Oaths must sign it.
We see businesses purchase documents marketed as certificates when an affidavit would meet the requirement. That creates an avoidable cost and may leave procurement teams questioning the document’s status.
A certificate has a different role. It starts a 12-month validity period on its issue date, so record that date in your compliance calendar and plan evidence collection before renewal pressure begins.
Build the B-BBEE verification evidence file
A verifier does not verify an intention, a management presentation or a total lifted from a spreadsheet. The agency will test the documents that support each scorecard claim.
Create a folder structure that mirrors the applicable scorecard. Give each file a clear name, period and document owner. Restrict edit access, but make retrieval simple when the verification team asks a follow-up question.
Your B-BBEE scorecard preparation file should normally include the following records:
● Ownership and voting-rights documents that support ownership claims.
● Director, management, payroll and demographic records for management-control claims.
● Learner agreements, training records, invoices and proof of payment for skills-development claims.
● Supplier spend ledgers, invoices and valid supplier B-BBEE evidence for procurement claims.
● Enterprise and supplier-development or socio-economic-development agreements, proof of payment, beneficiary evidence and proof of implementation.
Reconcile claimed amounts to the accounting records before submission. Where the applicable Code requires it, exclude VAT from the claimed amount. The reasoning matters: an invoice may prove that you received a service, but the general ledger and payment evidence establish the amount you actually incurred and paid.
Worked example: the missing payment trail
Take a Johannesburg manufacturer with annual turnover of R68 million and a claimed R250,000 supplier-development contribution. Its procurement manager retained the signed beneficiary agreement and an invoice, while finance held the payment confirmation under a different cost centre.
The business initially presented the agreement and invoice only. A verifier would still need evidence that the payment occurred and that the beneficiary received and implemented the support. The company should assemble the ledger extract, bank payment proof and implementation records before the verification appointment.
If the records cannot support the full R250,000, the company should reduce or remove the claim rather than ask the agency to accept a narrative. Next cycle, it should make the finance controller responsible for closing the evidence pack within 30 days of every contribution.
Reconcile ownership, people and spend before submission
The most common preparation failure is not a missing document. It is a mismatch between the scorecard claim, the financial records and the operational reality.
For ownership, check that the ownership documentation and voting position support the claim for the measurement period. For management control, reconcile the organisational chart to director records, payroll information and demographic data.
For skills development, do not rely on a training calendar. Match each learner or employee record to the training evidence, invoice and payment record. The same discipline applies to preferential procurement: match supplier spend in the ledger to invoices and valid supplier B-BBEE evidence.
Worked example: a retailer that counted the wrong spend
Consider a Durban retailer with 12 staff, R1.2 million in monthly payroll and supplier spend spread across more than 80 vendors. Its draft scorecard included R600,000 from a supplier ledger, but several entries were estimates raised before month-end invoices arrived.
The retailer should not treat a purchase order or estimate as final spend evidence. It needs the relevant invoice, ledger entry and supplier B-BBEE evidence, then must apply the applicable Code treatment to the claim, including the VAT position where required.
A better process would require procurement to capture supplier evidence when it onboards a vendor, rather than chasing expired or missing documents at year-end. The finance manager should also reconcile the procurement schedule to the ledger before the verification agency receives it.
Choose the verification agency with care
For entities that require verification, appoint an agency with a current scope accredited by the South African National Accreditation System, SANAS. Check the agency in SANAS’s Conformity Assessment Bodies database before engagement.
Do not assume an agency’s historic accreditation remains current or covers the work you need. Scope matters because B-BBEE verification requires an accredited verification route, not simply a consultant’s assurance that it understands the scorecard.
Give the agency one controlled document set. Keep a register of every request, response and revised calculation. This record protects your governance process and prevents different departments from supplying inconsistent versions of the same document.
A material ownership or operational change after certificate issue requires re-verification. Review your certificate after acquisitions, ownership changes, material shifts in operations or changes that affect the evidence underlying the scorecard.
Treat fronting risk as a governance issue
B-BBEE preparation must reflect actual economic participation and implementation. Paper-only ownership, token appointments and benefit diversion are fronting indicators.
False status claims, false evidence provided to a verification professional and fronting are offences. On conviction, the consequences can include a fine, up to 10 years’ imprisonment, or both; a juristic person may face a fine of up to 10% of annual turnover and exclusion from state business for 10 years.
That is why directors should review the evidence file before submission. The board does not need to inspect every invoice, but it should understand the scorecard claims, significant judgement calls and controls over supporting evidence.
As of September 2026, we found no change in the official materials reviewed between 23 March 2025 and 23 September 2026 that alters the verification validity approach set out in the B-BBEE Commission’s 2022 practice guide. Your team should still check the current applicable Code, sector requirements and affidavit form before relying on any document.
B-BBEE audit preparation checklist
Before your verification date, confirm that you can answer each of these questions:
● Have we identified the correct sector code or confirmed that the Generic Codes apply?
● Does our annual turnover place us in the correct EME, QSE or large-enterprise category?
● Do we need an affidavit, CIPC certificate or accredited B-BBEE verification?
● Can we trace each scorecard claim to agreements, invoices, accounting records and proof of payment?
● Have we checked the verification agency’s current SANAS accreditation scope?
● Have directors reviewed material changes since the last certificate issue date?
Frequently Asked Questions
Is a B-BBEE audit the same as B-BBEE verification?
No. B-BBEE verification tests and substantiates scorecard information under the Verification Manual. It does not replace a statutory financial audit.
Does every South African company need a B-BBEE certificate?
No. Under the Generic Codes, an EME may use a sworn affidavit or CIPC certificate. A QSE that is at least 51% black owned may also use a sworn affidavit, subject to the applicable requirements.
How long does a B-BBEE certificate remain valid?
A verification certificate has a 12-month validity period from its issue date. Material ownership or operational changes after issue require re-verification.
What evidence will a B-BBEE verification agency request?
The request depends on the applicable Code and your claims. It commonly covers ownership, management and payroll records, training evidence, supplier spend records, invoices, payment proof and beneficiary implementation evidence.
A disciplined B-BBEE verification process gives management more than a certificate. It gives the enterprise a clearer record of how its ownership, people, supplier relationships and development commitments stand up to scrutiny. Speak With Our Team to prepare your evidence file and verification plan.
