The B-BBEE skills development element is the second priority category on the Generic scorecard — worth 25 points, layered with a sub-minimum threshold that triggers an automatic band discount when missed, and structurally tied to Skills Development Levy (SDL) payments that most corporates are already making to SARS. The apparent simplicity — “we pay the levy anyway” — obscures the counting mechanics that actually deliver scorecard recognition. Levy payment does not equal scored points.
This guide walks through how the scored sub-indicators translate SDL spend into scorecard recognition, how learnership and internship programmes drive the substantive point contribution, and what the sub-minimum discipline looks like in practice. The pillar reference for B-BBEE scorecard elements in South Africa sits alongside this for the broader scorecard context.
Quick Answer
The B-BBEE skills development element scores four sub-indicator groups totalling 25 points on the Generic scorecard: training spend on black employees (up to 8 points, benchmarked at 6% of the leviable amount), training spend on black people with disabilities (up to 4 points), learnership and internship placements for black employed people and black unemployed people (up to 4 points each), and the absorption of programme completers into permanent employment (up to 5 points). Category F/G bonus recognition applies for programmes reaching unemployed learners. The priority sub-minimum requires 40% of available sub-points — most corporates target 65%-80% of the total 25 to hold rating tier comfortably.
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The Four Sub-Indicator Groups That Add Up to 25 Points
The Amended Codes break this scorecard area into four sub-indicator groups plus a bonus overlay. Each group measures a different dimension of what training investment actually delivers to black beneficiaries — spend intensity, disability inclusion, structured programme participation, and post-programme employment outcomes.
Training spend is the largest single sub-indicator. The Codes measure the corporate’s training spend on black employees against a 6% target of the leviable amount (the payroll base used for SDL calculation). Meeting the 6% target delivers the full 8 points; performance below the target scales linearly to zero. The definition of “training spend” is broader than SDL contributions alone — internal training, external training, learnership-related costs, mentorship programmes, and legitimate opportunity costs all count.
Training spend on black people with disabilities is a separate sub-indicator worth up to 4 points, benchmarked at 0.3% of the leviable amount. This sub-target is often left unaddressed because it requires operational HR work (disability disclosure frameworks, workplace accommodations, targeted training programmes) rather than simply reallocating existing training budgets.
Learnership, internship, and apprenticeship placements are captured across two sub-indicators — one for black employed learners (up to 4 points, benchmarked at 2.5% of workforce headcount) and one for black unemployed learners (up to 4 points, benchmarked at 2.5%). The programmes must be registered with the relevant SETA and meet defined structure requirements to score.
Absorption is the fourth sub-indicator — up to 5 points for the percentage of programme completers who become permanent employees. This sub-indicator often drives corporate behaviour more than any other: the difference between a training programme that delivers absorption and one that doesn’t is the difference between 15-20 points on the total scorecard and 8-12 points.
How SDL Spend Translates to Scored Points
The SDL is a 1% payroll levy paid monthly to SARS, of which 80% flows to the relevant SETA (with 20% retained by the National Skills Fund). Corporates recover a portion of the SETA-allocated 80% through mandatory and discretionary grants where they meet specific compliance criteria — including submission of the annual Workplace Skills Plan (WSP) and Annual Training Report (ATR).
The scorecard does not measure SDL payment or grant recovery directly. It measures the corporate’s total training spend on black beneficiaries against the 6% leviable amount target. The SDL is one component of this spend but not the whole picture — a corporate paying 1% SDL and recovering the mandatory grant still has to demonstrate additional training investment to reach the 6% target.
The training spend calculation includes: direct programme costs, learner stipends, accommodation and travel costs for external training, salaries of internal trainers proportionate to training delivery time, learning material development costs, and legitimate opportunity-cost calculations for time spent on structured programmes. The Department of Higher Education and Training’s National Skills Development Plan sets out the policy framework within which SETA-registered programmes qualify for scorecard recognition.
Where a corporate’s total training spend falls below the 6% target, sub-indicator scoring adjusts proportionally. A corporate spending 3% of the leviable amount on black-beneficiary training scores 4 of 8 points on that sub-indicator (proportional to the 6% benchmark).
B-BBEE Skills Development Element Priority Sub-Minimum Rules
This component sits as one of three priority scorecard categories on the Generic scorecard — alongside Ownership and Enterprise & Supplier Development. Priority-category status means the sub-minimum threshold applies independently of the total-point calculation, and missing it triggers an automatic one-band rating discount regardless of overall performance elsewhere.
The specific rule requires the corporate to achieve at least 40% of the available sub-points on the priority category. The arithmetic works out to roughly 10 of the 25 available points as the sub-minimum floor — though the exact threshold depends on the specific weighting applied under the corporate’s applicable sector code.
| Rating Ambition | Target Score (of 25) | Realistic Programme Profile |
|---|---|---|
| Top tier (Level 1) | 20-25 | 6%+ spend + full learnership numbers + strong absorption + disability programme |
| Second band (Level 2) | 16-20 | 5%-6% spend + strong learnership numbers + moderate absorption |
| Third band (Level 3) | 13-16 | 4%-5% spend + moderate learnership + some absorption |
| Fourth band (Level 4) | 10-13 | Sub-minimum threshold cleared + moderate spend |
| Fifth band (Level 5) | Below 10 | Sub-minimum threshold at risk — priority discount likely |
The scored ranges above assume the sub-minimum clears independently. Where a corporate targets 15 total points (upper third band) but misses the sub-minimum threshold, the actual rating drops by one band regardless of the total. The sub-minimum rule is why credible programmes target 65%-80% of the available 25 points as an operational floor — the buffer above 40% of sub-points protects the rating against natural year-on-year variance.
The Absorption Multiplier
Absorption is the sub-indicator that most often separates strong training programmes from weak ones. A learnership programme that produces 30 completers per year and absorbs 20 of them into permanent employment scores higher than a programme producing 60 completers with 5 absorbed. The Codes reward the outcome (permanent employment) rather than the input (programme size). Corporates that design their programmes around absorption from the start typically outscore corporates that scale programme size without an absorption strategy.
Designing a training programme and want the absorption-multiplier modelled properly before the intake numbers get finalised? Book a programme-design diagnostic review →
Practical Training Programme Design
A well-structured training programme runs across three interlocking design workstreams: the training-spend allocation strategy, the learnership and internship pipeline, and the absorption pathway. The three workstreams share the same budget envelope but optimise for different sub-indicators.
| Workstream | Typical Budget Share | Sub-Indicator Target |
|---|---|---|
| Training-spend allocation (existing employees) | 45%-55% of programme budget | 6% leviable amount target on spend sub-indicator |
| Learnership and internship pipeline | 30%-40% of programme budget | 2.5% headcount target on placement sub-indicators |
| Absorption pathway (post-programme employment) | 10%-15% of programme budget | Absorption percentage on completer sub-indicator |
| Disability-specific programme | 5%-10% of programme budget | 0.3% leviable amount + workforce disclosure framework |
The exact allocation depends on the corporate’s starting sub-indicator performance profile. A corporate strong on training spend but weak on absorption typically shifts budget from workstream one to workstream three; a corporate strong on absorption but weak on learnership numbers shifts budget in the opposite direction. The programme design has to run the scorecard model with the corporate’s actual sub-indicator baseline before the budget allocation is finalised.
Common Implementation Pitfalls
Confusing SDL payment with scored training spend. A corporate paying the 1% SDL and recovering the mandatory grant still needs to demonstrate additional training investment to reach the 6% target. Treating SDL payment as sufficient for scorecard recognition typically caps the training-spend sub-indicator at 2-3 of 8 points.
Running learnership programmes without SETA registration. Learnership, internship, and apprenticeship programmes must be registered with the relevant SETA and meet the defined structure requirements to score. Programmes that look like learnerships operationally but are not formally registered do not deliver scorecard recognition — the verification agency checks the SETA registration status at every cycle.
Ignoring the disability sub-target. The 0.3% leviable amount target for training spend on black people with disabilities is often overlooked because it requires operational HR work rather than budget reallocation. Corporates with an established disability disclosure framework typically pick up 2-4 sub-indicator points at low incremental cost.
Failing to close the absorption loop. Training programmes that produce completers without a defined pathway to permanent employment typically deliver strong learnership sub-indicator scores but weak absorption scores. The 5-point absorption category is often the difference between a mid-band and a strong-band rating.
The Priority Discipline
Corporates that clear the sub-minimum by a comfortable margin typically deliver 30%-40% higher scored performance across other elements too, because the programme design discipline required for a strong training component tends to correlate with disciplined data management and structured operational cadence. This scorecard area is often the first place the operational discipline shows — or fails to show — at verification.
Who This Article Is NOT For
EMEs below R10 million turnover. The Codes rate EMEs at default levels with no measured training scorecard applying. The mechanics in this guide do not translate to the EME regime.
QSEs comfortable with the sworn-affidavit route. A 51%-or-more black-owned QSE between R10m and R50m qualifies automatically for the second band by affidavit. Working through the full training scorecard scoring for a QSE that already qualifies via affidavit is inefficient — the affidavit route delivers a stronger rating outcome at materially lower administrative cost.
Corporates below the SDL threshold. Employers with an annual payroll below R500,000 are exempt from SDL payment and typically fall outside the substantive training scorecard measurement framework. The counting rules and target thresholds work differently at this scale and warrant a bespoke advisory conversation.
Corporates with no meaningful workforce transformation objective. The programme design described here presumes a genuine intent to deliver training that produces long-term workforce transformation outcomes — not merely scorecard recognition. Corporates whose training investment is purely compliance-driven typically deliver weaker scored results because the substantive programme quality shows through at verification.
How Insignis Runs Training Programme Advisory
Insignis runs training programme advisory engagements where the scorecard-recognition design and the training programme design run as a single integrated exercise rather than sequentially. The training-spend allocation, the learnership pipeline, and the absorption pathway are optimised together against the corporate’s specific sub-indicator baseline, not treated as independent budget lines.
Dr. Este Welman leads these engagements with a Chartered Accountant (SA) background, a PhD in Economic Transformation from the Da Vinci Institute, an M.Comm in Taxation from North-West University, a B-BBEE Management Diploma from Wits, and SAICA membership. Her advisory work brings together the scorecard scoring formulas, the SETA registration mechanics, and the operational HR framework that keeps the programme delivery cadence consistent across annual cycles.
The Insignis approach for programme engagements runs a scoring-baseline diagnostic that maps the current sub-indicator performance, identifies the highest-return interventions across the four groups, and produces a 12-month programme design that co-ordinates the SETA registration cycle, the annual WSP/ATR submission cadence, and the scorecard verification measurement date. Engagement scope is typically 0.6%-1.2% of annual training budget for the delivery phase, plus a modest annual retainer for scorecard-and-SETA co-ordination.
Ready to run the scoring-baseline diagnostic before the next training programme intake locks? Talk to Dr. Welman about the integrated scoring-and-programme diagnostic →
Frequently Asked Questions
How is the 6% training spend target calculated?
The 6% target measures the corporate’s total training spend on black beneficiaries against the leviable amount — the payroll base used to calculate the levy paid to SARS. A corporate with an R80m leviable amount would need to demonstrate R4.8m in training spend on black beneficiaries to clear the 6% target for the full 8 points on that sub-indicator.
The spend calculation is broader than SDL contributions alone. Internal training, external training, learnership-related costs, mentorship programmes, and legitimate opportunity-cost calculations for time spent on structured programmes all count towards the total.
Do learnership and internship programmes require SETA registration?
Yes. Learnership, internship, and apprenticeship programmes must be registered with the relevant SETA and meet the defined structure requirements to score on the scorecard sub-indicators. Programmes that look like learnerships operationally but are not formally registered do not deliver scorecard recognition — the verification agency checks the SETA registration status at every cycle.
The registration process typically takes 3-6 months from initial application to formal registration, so programmes need to be designed and submitted well ahead of the intended intake cycle.
What counts as absorption for scorecard purposes?
Absorption is the placement of a programme completer into permanent employment — either with the corporate that ran the programme or with another employer under a documented placement arrangement. The Codes require the placement to be substantive rather than nominal, which means employment terms consistent with the corporate’s standard permanent employment framework rather than a fixed-term arrangement designed to trigger scorecard recognition.
The absorption percentage is measured against total completers in the measurement period. Corporates targeting the full 5 points typically aim for absorption rates of 60%+ of completers.
How does the disability sub-target actually work?
The 0.3% leviable amount target measures training spend specifically on black employees with disabilities. The employees must have formally disclosed a disability under the EE Act framework — employees who have not disclosed do not count towards the sub-target regardless of the substantive circumstances.
Corporates that want to improve this sub-indicator typically invest in disability-inclusion frameworks that make disclosure safer and more attractive to employees — workplace accommodations, non-discrimination policies, and dedicated support pathways. The scored improvement typically comes over 2-3 years rather than in a single verification cycle.
Can training spend on external contractors count towards the scorecard?
Generally no. The scored training spend measures investment in the corporate’s own workforce (employees and enrolled learners) rather than in external contractors, service providers, or supplier employees. Training provided to supplier-side beneficiaries can sometimes count towards Enterprise & Supplier Development sub-indicators, but typically not towards this category.
The distinction matters at programme design time. Corporates that plan to train service providers as part of a broader ecosystem investment should design the programme against the ESD scorecard mechanics rather than the training scorecard mechanics — the counting rules and target thresholds are different.
What happens if a learner drops out before completing the programme?
Drop-outs affect the absorption sub-indicator scoring because the completer denominator changes. A programme with 40 intake, 30 completers, and 20 absorbed scores at 20/30 = 67% absorption. The same programme with 40 intake, 20 completers, and 15 absorbed scores at 15/20 = 75% absorption — the improved percentage reflects the smaller completer pool.
Drop-outs also affect the training spend calculation because unspent budget for departed learners cannot be recognised as training investment. Well-run programmes plan for a 20%-30% drop-out rate and build the intake numbers accordingly to hit the target absorption headcount.
Model the Sub-Indicator Arithmetic Before the Training Programme Locks
The scorecard model runs the projection across the full programme lifecycle, maps the training-spend allocation to the learnership pipeline and the absorption pathway, and produces the analytic package the training committee needs to commit to a specific programme design and budget envelope.
Dr. Este Welman or a senior Insignis advisor will run the initial scoring-baseline diagnostic. No obligation. We will get back to you within 24 hours of your enquiry.
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About the Author — Dr. Este Welman, CA(SA)
Founding Director, Insignis Solutions. Chartered Accountant (SA), PhD in Economic Transformation (Da Vinci Institute), M.Comm in Taxation (North-West University), B-BBEE Management Diploma (Wits), SAICA member.
Dr. Welman leads training programme engagements where the scorecard-recognition design and the substantive training-programme design run as a single integrated exercise, with particular focus on the absorption sub-indicator mechanics that determine whether the total component score reaches the sustainable rating tier the corporate is targeting.