B-BBEE transport logistics compliance is the last corner of the economy still measured against the pre-2013 rulebook, and most operators in the industry do not realise it.
Every other gazetted instrument was aligned to the Amended Codes of Good Practice years ago. This one was not. It still runs on the framework that existed before 2013, which means different size bands, different rules, and one significant absence that works in your favour right now. If you have not confirmed which of the B-BBEE sector codes governs your operation, that is the starting point.
It also means the eventual alignment will not be a gentle adjustment. It will be a step change, and the Charter Council has said it intends to bring it in without a transitional period.
Quick Answer
B-BBEE transport logistics compliance falls under the Integrated Transport Sector Code, gazetted as Gazette 32511 and effective from 21 August 2009. It is the only instrument never aligned to the Amended Codes, so it still uses the old size bands — exemption below R5 million and small enterprise up to R35 million — and carries no priority elements and no discounting principle. There is no affidavit route. Eight sub-sectors each carry their own scorecard and their own targets.
Not sure which of the eight sub-sectors you fall into? Send us your revenue mix and we will place you →
What B-BBEE Transport Logistics Compliance Requires
Eight sub-sectors sit inside this instrument, and each one carries a separate scorecard with its own targets. Identifying the right one is not administrative housekeeping — it determines the numbers you are measured against.
The eight are bus commuter and coach services, the taxi industry, road freight, the public sub-sector, maritime services, forwarding and clearing, rail, and domestic aviation. A single group operating a fleet, a clearing desk and a warehousing arm can straddle more than one.
Targets vary meaningfully between them. The bus commuter sub-sector, for instance, was set a 35% black ownership target to be reached within five years of gazetting — well above the generic position at the time and above most sub-sectors here.
The size bands are the old ones
This is the provision that catches operators out most often, and it runs in the expensive direction.
| Measure | Amended generic Codes | Integrated Transport Code (2009) |
|---|---|---|
| Exempt micro enterprise | Below R10 million | Below R5 million |
| Small enterprise band | R10m to R50 million | R5m to R35 million |
| Large enterprise | Above R50 million | Above R35 million |
| Affidavit route for small entities | Available | Not available |
| Priority elements | Three, with sub-minimums | None |
| Discounting principle | Applies | Does not apply |
A haulage business turning over R8 million is a small enterprise here with a full scorecard obligation, while an identical business measured generically would be exempt. And because the affidavit mechanism arrived with the Amended Codes, it is not available under this instrument. Small operators need a verification certificate from an accredited agency, not a free sworn statement.
We have seen businesses download an affidavit template, sign it, and present it to a client for two years running before someone in a procurement department queried it. The document was worthless the day it was signed.
The affidavit that is not valid
The sworn affidavit route for smaller entities was introduced by the Amended Codes. Because this instrument predates them and was never aligned, operators measured under it cannot use one. A business below R5 million still needs a certificate issued by an accredited agency. Presenting an affidavit to a corporate client is not a shortcut — it is an invalid document that will fail the moment it is properly checked.
The Absence That Currently Works in Your Favour
Here is the part that no operator should take for granted, because it is the thing most likely to disappear.
This instrument has no priority elements. There is no ownership sub-minimum, no skills sub-minimum, no supplier development sub-minimum, and consequently no discounting principle. Miss a target under any element and you lose the points for that element — nothing more. In every other gazetted instrument, missing a single sub-minimum costs a full recognition level regardless of total score.
Smaller entities get a second concession on top. A qualifying entity may select any four scorecard elements and be measured on those alone, each carrying 25 points. Choosing the four you already perform well on is entirely legitimate.
Read together, those two features make this the most forgiving gazetted instrument in the economy. An operator with weak ownership and strong procurement can still certificate well, which would be impossible almost anywhere else.
The strategic point follows directly. If your current level depends on those concessions, it depends on a regime that has been under active revision since 2016.
Current level resting on the choose-four scorecard? Ask us to model where you would land under a full five-element scorecard →
Where the Alignment Process Stands
The history matters, because it explains why experienced operators have stopped reacting to announcements.
All gazetted instruments were required to align with the 2013 amendments. A draft for this industry was released in February 2016 and never published. The Minister of Transport appointed a new Charter Council in May 2023 with an explicit alignment mandate, and the Council indicated the amended instrument would be published by the end of that year, effective from 1 March 2024, with no transitional period.
That date passed without a gazette. As of the most recent information available, the 2009 instrument remains the operative one and the amended version has not been published.
What has changed is the level of detail circulating. A set of resolutions summarised through the accreditation body has been discussed across the industry during 2026, and while none of it is law until gazetted, the direction is consistent enough to plan against.
What the reported resolutions point toward
Treat the following as proposals rather than requirements. They have not been gazetted, and details change during finalisation.
Ownership targets are reported to be moving up substantially, toward 40% black ownership with a 20% black women component. The recognition of past ownership deals — the principle that once empowered means always empowered — is reported to fall away, which would force a re-examination of any structure relying on a historical transaction. Modified flow-through is reported to be excluded as a methodology.
On the social side, contributions are reported to require geographic targeting, with half the target directed toward rural areas and townships rather than general philanthropy.
None of that is settled. All of it points the same way: toward the generic framework, with priority elements and discounting attached.
Plan for the harder regime, certificate under the current one
The sensible position for an operator is to keep certificating under the 2009 instrument while building the scorecard you would need under an aligned one. Ownership takes the longest to move and is where the reported changes bite hardest. A structure begun now is a structure that survives the transition; one begun after the gazette lands will not, because no transitional period is proposed.
Getting the Sub-Sector Right
Because each of the eight carries its own targets, placing a business correctly is the highest-value hour spent on any engagement here. It is also the step most often skipped.
The difficulty is that modern operators rarely sit neatly in one box. A group might run its own fleet, hold a clearing licence, operate a bonded warehouse and sub-contract long-haul work to owner-drivers. Four activities, potentially two or three different scorecards.
The test is dominant activity measured by revenue, not by headcount, asset value or what the company name suggests. A business describing itself as a haulier may earn most of its margin from clearing work, and the applicable scorecard follows the money.
Where a group is genuinely split, the answer is usually to establish the position for each measured entity separately rather than force a single view across the group. That is more work at the outset and considerably less work than unwinding three years of measurement against the wrong targets.
Get it confirmed in writing
We ask the verification agency to confirm the sub-sector determination in writing before any modelling starts. Agencies are generally willing, and the document costs nothing.
Its value shows up later. When a procurement team or a state client queries which scorecard was applied, a written determination from the agency that issued the certificate settles the question immediately. Without it, the discussion runs on assertion.
Year-End Timing and the Coming Gazette
One planning point deserves attention precisely because no transitional period has been proposed.
If an amended instrument is gazetted with immediate effect, the measurement year in progress at that moment becomes the awkward one. A business with a February year-end and a gazette landing in March has almost a full cycle to adjust. One with a March year-end has none.
Nobody should restructure a financial year around a gazette that has not appeared. But where a year-end is already under discussion for commercial reasons, this belongs in the conversation.
The more practical response is to hold a current certificate for as long as the rules allow. A certificate issued under the present instrument remains valid for its stated period, which buys planning time on the far side of any change. Letting one lapse in the month before a gazette would be an expensive piece of timing.
Why B-BBEE Transport Logistics Ratings Fail at Verification
Four causes recur across mandates in this industry, and none of them are about strategy.
The sub-sector is assumed rather than tested. A group with a fleet, a clearing desk and a warehouse may be measured against the wrong scorecard for years. Targets differ between sub-sectors, so the error is not cosmetic.
Owner-driver arrangements are never mapped. Much of the industry runs on contracted owner-drivers, many of them black-owned micro enterprises. Their certificates are rarely collected, so procurement spend that would score well records against unrated suppliers.
Compulsory training goes unclaimed. Dangerous goods handling, defensive driving and load securement are delivered because operations and insurers demand them. The attendance and completion evidence needed for the skills element is frequently never captured.
The affidavit assumption persists. Small operators arrive at a tender with a sworn statement that carries no weight under this instrument, and discover it at the point of disqualification.
What Changes When the Structure Is Established First
The figures below come from a composite of road freight and forwarding mandates across Gauteng and KwaZulu-Natal.
| Position | Before engagement | After 18 months |
|---|---|---|
| Recognition level | Level 6 | Level 3 under current rules |
| Sub-sector applied | Road freight, assumed | Forwarding and clearing, confirmed in writing |
| Owner-driver spend traced | R2.4 million | R21.7 million traced and claimed |
| Compulsory training claimed | R0 of R680 000 delivered | R610 000 evidenced and claimed |
| Certification basis | Affidavit, invalid | Verified certificate from an accredited agency |
| Modelled position under alignment | Never assessed | Level 5 projected, gap plan in place |
The last line is the one that should hold a board’s attention. A business sitting comfortably at Level 3 today projects to Level 5 under the aligned regime, and closing that gap takes longer than the notice period being proposed.
Who This Is NOT For
Operators genuinely below R5 million. You still need a certificate rather than an affidavit, but the exercise is small and an accredited agency handles it directly. Advisory support adds little at this scale.
Businesses with no intention of revisiting ownership. The reported changes concentrate on the ownership element. If a transaction is permanently off the table, most of what a strategist can offer here is unavailable to you.
Anyone hoping to certificate quickly on a historical deal. Reliance on a past transaction is precisely what the reported resolutions target. Building a strategy on continued recognition of an old structure is building on the provision most likely to be removed.
Cross-border carriers without a local measured entity. Without locally recognised revenue, employees and procurement, there is no scorecard to construct.
Who this does suit: freight operators, forwarding and clearing agents, bus and coach companies, rail and aviation service businesses above R5 million, particularly those whose current level depends on the absence of priority elements or on the choose-four scorecard.
The Insignis Approach to B-BBEE Transport Logistics Engagements
Every engagement here runs on two scorecards at once. We build the position under the 2009 instrument, because that is what you certificate against today, and we model the same business under an aligned framework with priority elements attached. The gap between those two numbers is the actual planning document.
Before either, we establish the sub-sector in writing against your revenue mix. Groups spanning haulage, warehousing and clearing frequently sit somewhere other than where they assume, and targets differ enough that the error changes the outcome.
Ownership restructuring in an asset-heavy, thin-margin industry is a financing and tax question long before it becomes a scorecard question. That is why the practice is led by a Chartered Accountant whose further qualifications run to a doctorate in Economic Transformation from the Da Vinci Institute and postgraduate tax specialisation at M.Comm level. Our B-BBEE consulting scope covers the full cycle from Centurion.
The gazetted instrument is public and worth having on file, particularly the sub-sector parts. The official notice for the transport sector codes of good practice hosts the full document set.
Board asking what alignment will cost you? Get both scorecards modelled side by side →
Frequently Asked Questions
Is the Integrated Transport Sector Code still in force?
Yes. The 2009 instrument gazetted under Gazette 32511 remains the operative one. It is the only gazetted sector code never aligned to the Amended Codes of Good Practice, and an amended version has been repeatedly announced but not published.
What are the size thresholds in the transport sector?
The old bands apply: exemption below R5 million in annual turnover, small enterprise between R5 million and R35 million, and large enterprise above R35 million. These are lower than the R10 million and R50 million bands in the Amended Codes.
Can a small transport business use a sworn affidavit?
No. The affidavit route was introduced by the Amended Codes, and because this instrument was never aligned it does not apply. Smaller operators require a certificate issued by an accredited verification agency.
Are there priority elements in the transport sector?
No. This instrument carries no priority elements and no discounting principle, so missing a target costs only the points for that element rather than a full recognition level. It is the only gazetted code in that position.
How many sub-sectors are there?
Eight: bus commuter and coach services, the taxi industry, road freight, the public sub-sector, maritime services, forwarding and clearing, rail, and domestic aviation. Each carries its own scorecard and its own targets.
What should operators do before the amended code is gazetted?
Continue certificating under the current instrument while modelling the business against an aligned framework. Ownership takes longest to move and is where the reported changes concentrate, and no transitional period has been proposed.
Two scorecards, one planning decision
A dual review confirms your sub-sector in writing, builds your position under the current instrument, and models the same business under an aligned framework with priority elements and discounting applied. You see the gap while there is still time to close it rather than after a gazette lands without notice.
No obligation. We will get back to you within 24 hours.
Request a dual scorecard review
Dr. Este Welman, CA(SA)
Founding Director, Insignis Solutions
Dr. Welman is a Chartered Accountant holding a PhD in Economic Transformation from the Da Vinci Institute, an M.Comm in Tax from North-West University, and a B-BBEE Management Diploma from Wits. She is a member of SAICA. Advising in an industry operating under a superseded framework calls for a particular discipline: building for the rules that are coming while certificating honestly against the rules that still apply.