Who Does the Property Sector Code Apply To?

The Property Sector Code applies to entities operating within the property industry, including:

• Property ownership and investment
• Property management
• Property development
• Letting and real estate services, and related property value chain activities

Why Turnover Thresholds Work Differently in Property

Unlike most other industries, the Property Sector doesn’t use a single turnover measure to determine whether a business needs a Sworn Affidavit or a full B-BBEE Certificate. Instead, it recognises that property businesses operate in different ways, so the applicable threshold depends on the type of entity you are.

Asset-Based Entities (Property Owners and Funds)

For these businesses, compliance is measured according to Nett Assets rather than turnover:

• EME: Nett Assets of less than R80 million – a Sworn Affidavit or CIPC Certificate applies.
• QSE: Nett Assets of more than R80 million but less than R400 million – a Sworn Affidavit applies to companies with at least 51% Black ownership; other companies need to be verified.
• Generic: Nett Assets of more than R400 million – a SANAS B-BBEE verification is required.

Service-Based Entities (Property Services Businesses)

These are measured on Annual Turnover:

• EME: Annual turnover of less than R10 million – a Sworn Affidavit or CIPC Certificate applies.
• QSE: Annual turnover of R10 million to R50 million – a Sworn Affidavit applies to companies with at least 51% Black ownership; other companies need to be verified.
• Generic: Annual turnover of more than R50 million – a SANAS B-BBEE verification is required.

Estate Agencies, Broking and Valuation Companies

This category has its own lower thresholds:

• EME: Annual turnover of less than R2.5 million – a Sworn Affidavit or CIPC Certificate applies.
• QSE: Annual turnover of R2.5 million to R35 million – a Sworn Affidavit applies to companies with at least 51% Black ownership; other companies need to be verified.
• Generic: Annual turnover of more than R35 million – a SANAS B-BBEE verification is required.

The practical takeaway is that a property-owning fund and an estate agency of a similar size could sit in completely different categories, simply because of how the sector classifies their activities. Applying the wrong threshold could mean submitting the wrong document altogether.

Ownership Targets Are Higher

Under the Property Sector Code, the Black ownership target for property owning companies is increased to 27%, compared to the standard Generic Codes targets. This is an important detail to factor into ownership planning, especially for asset-based entities looking to strengthen their scorecard.

A Sector-Specific Element: Economic Development

One of the more notable differences in the Amended Property Sector Code is the inclusion of an additional scorecard element: Economic Development. This measures investment in under-resourced areas and contributions towards economic development programmes.

This addition makes the property scorecard more investment-focused than the Generic Codes and encourages property businesses to play a meaningful role in property-driven economic upliftment, not just ownership transformation.

Why This Matters for Your Business

Getting your classification right, whether you’re asset-based, service-based, or an estate agency, and knowing your correct threshold, ensures you submit the right documentation the first time. It also means your scorecard reflects the sector-specific opportunities, like Economic Development, that could improve your B-BBEE level.

Applying Generic Code assumptions to a property business can lead to incorrect Affidavits, unnecessary verification costs, or a scorecard that doesn’t reflect your business accurately.

Need Help Confirming Your Property Sector Classification?

Elevate Advisory Partners can help you confirm which threshold category applies to your business, prepare the correct documentation, and make sure your B-BBEE approach is aligned with the Property Sector Code. Contact us at info@elevateadvisory.co.za or visit www.elevateadvisory.co.za to get started.

This article covers the Property Sector specifically. Want the full picture across all industries, including MAC, ICT, Tourism, Forestry, Construction, Financial, Agricultural, Defence, Transport, Legal, and CA Sector Codes? Download our complete ebook, “B-BBEE Industry Thresholds Explained,” here.

Frequently Asked Questions

Do all property businesses use the same turnover threshold?

No. The Property Sector Code recognises three categories: asset-based entities (measured on Nett Assets), service-based property businesses (measured on Annual Turnover), and estate agencies, broking or valuation companies (which have their own, lower turnover thresholds).

What’s the Black ownership target for property owning companies?

It’s 27%, which is higher than the Generic Codes target.

What is the Economic Development element, and why does it matter?

It’s an additional scorecard element specific to the Property Sector Code, measuring investment in under-resourced areas and contributions to economic development programmes. It makes the property scorecard more investment-focused than the Generic Codes.

How do I know if my business is “asset-based” or “service-based” for B-BBEE purposes?

This depends on how your business generates income and holds property, for example, whether you primarily own and invest in property versus provide property-related services. If you’re unsure, it’s worth getting professional guidance to confirm your classification.

Can my property business use a Sworn Affidavit instead of a full certificate?

It depends on your category and threshold. In most cases, a Sworn Affidavit is only available to EMEs, and to QSEs with at least 51% Black ownership. Businesses above the relevant threshold, or QSEs with less Black ownership, will need to be verified by a SANAS accredited verification agency.