OPEN LETTER: REQUEST FOR AN INDEPENDENT B-BBEE BENEFICIARY IMPACT ASSESSMENT

To:
The Minister of Trade, Industry and Competition
The B-BBEE Commission

Dear Minister and Commission

B-BBEE is justified as a measure that advances equality and broad economic participation. The public should therefore have access to independent, disaggregated evidence showing who receives its benefits and whether it achieves its stated purpose.

We request that a credible independent institution assess:

1. the actual beneficiaries of measurable B-BBEE benefits, divided by household income and wealth;
2. the value and distribution of benefits arising through ownership, procurement, management, skills development, enterprise development and related measures;
3. the proportion of benefits reaching poor and lower-income households;
4. whether particular measures are effective, necessary and proportionate;
5. whether Government considers it fair and rational to treat white South Africans less favourably because they are white and, if so, the evidence and legal basis showing why that differentiation remains fair, necessary and proportionate under section 9 of the Constitution and ICERD's limits on special measures; and
6. the objective criteria for periodic review, reform and eventual termination.

SIX QUESTIONS ON RACE VERSUS PRESENT-DAY DISADVANTAGE

We also ask Government to answer each of the following questions separately and with measurable evidence:

1. What evidence demonstrates that race remains a sufficiently accurate proxy for present-day disadvantage in 2026?

2. Why should an affluent black male potentially receive remedial preference over an economically disadvantaged white male solely because of their racial classification?

3. Has Government modelled alternatives based on actual disadvantage—income, household wealth, education, unemployment, geography or family circumstances—instead of, or alongside, race?

4. What measurable outcomes will show that race-based remedial measures have achieved their purpose and can be reduced or ended?

5. Why do the 2025 sector-target percentages explicitly exclude white males without disabilities rather than assessing each person's actual disadvantage?

6. How does Government ensure that measures intended to advance people disadvantaged by unfair discrimination do not become permanent racial categories detached from present circumstances?

The complete methodology, source data, assumptions, limitations and findings should be published in an accessible format. The assessment should distinguish eligibility from actual benefits received and should not rely only on aggregate racial ownership percentages.

We respectfully request a written response addressing each numbered question separately within 30 calendar days of receipt.

Supporting research and sources:
https://justicesa.com/en/campaign/show-us-the-evidence/evidence/where-white-south-africans-miss-out

Campaign and petition:
https://justicesa.com/en/campaign/show-us-the-evidence

This request is made in support of evidence-based government, equal dignity and transparent public policy.

Kind regards

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