On 3 August 2026, National Treasury and the South African Reserve Bank (SARB) published the Draft Crypto Asset Manual for cross-border activities for public comment.
The Manual provides further detail on how the proposed framework would apply to cross-border crypto asset transactions, including how certain transactions would be classified, authorised and reported to SARB’s Financial Surveillance Department (FinSurv).
This moves the conversation forward.
The question is no longer simply whether crypto assets will fall within South Africa’s capital flow management framework.
It is: Where does the regulatory border actually sit when crypto moves?
What has changed since April?
The April Draft Regulations established the broader framework for bringing crypto assets within South Africa’s capital flow management regime.
But they did not provide all of the practical detail needed to understand how these principles would apply to specific crypto transactions.
That became particularly important during the public consultation.
In May, National Treasury and SARB acknowledged concerns raised around the treatment of crypto assets and their cross-border movement. They indicated that a separate framework would be developed to provide greater clarity on cross-border crypto transactions.
The August Draft Manual is the next step in that process.
Rather than revisiting the broader capital flow management framework, it gives us something more useful for practical purposes: specific proposed transaction scenarios.
What does the August Manual add?
One of the most useful features of the Draft Manual is that it moves beyond broad principles and sets out how different crypto asset movements would be treated.
The Manual identifies the point at which certain transactions involving a domestic Authorised CASP and an offshore party or wallet would be regarded as an import or export of capital.
It also provides transaction examples in Table 2, distinguishing between domestic transactions, imports and exports of capital, and the corresponding reporting treatment.
This is where the proposed framework becomes much easier to understand.
The focus is not simply on whether crypto is involved, it is on where the asset is moving, who is involved and whether that movement results in a cross-border inflow or outflow.
So, what actually makes a crypto transaction “cross-border”?
The Draft Manual proposes that crypto asset transactions will be deemed an import or export of capital at the point where crypto assets are transferred:
- between a domestic Authorised CASP and an offshore CASP; or
- from a domestic Authorised CASP to a non-custodial wallet,
where the transaction results in a cross-border inflow or outflow.
That proposed distinction is important.
A crypto transaction does not automatically become cross-border simply because the asset is digital or because the parties use blockchain infrastructure.
The proposed framework instead looks at the movement of value across the domestic boundary.
For example, the Manual treats transactions between Authorised CASPs as domestic transactions. Its examples include the transfer of crypto between a resident's South African custodial wallet and another South African Authorised CASP.
The position changes where crypto moves from a domestic Authorised CASP into the offshore environment.
A transfer from a domestic custodial wallet to an offshore CASP, for example, is treated as an export of capital and an outward flow for reporting purposes under the relevant conditions set out in the Manual.
This gives businesses a much clearer indication of where the proposed regulatory boundary lies.
Why does the non-custodial wallet point matter?
This is arguably one of the most interesting aspects of the proposed framework.
A non-custodial wallet is fundamentally different from an offshore bank account or custodial crypto exchange. The user controls the private keys and the associated crypto assets directly.
The Draft Manual nevertheless specifically identifies a transfer from a domestic Authorised CASP to a non-custodial wallet as a transaction that can constitute an export of capital where it results in a cross-border outflow.
This matters because the regulatory framework is not dependent on the recipient being another regulated financial institution. The relevant transaction can involve a domestic regulated intermediary on one side and a wallet controlled directly by the user on the other.
That raises a practical compliance question for CASPs:
How do you determine the regulatory character of a transaction when the destination is a non-custodial wallet rather than another regulated institution?
The Manual's proposed approach places significant responsibility on the domestic Authorised CASP through which the transaction is facilitated.
The CASP must be able to identify and record information relevant to the transaction, including the originator and beneficiary wallet identifiers, transaction hash, crypto asset amount, exchange rate, Rand equivalent and reporting category.
The result is that the regulatory treatment of an on-chain transaction cannot be considered separately from the information surrounding it.
Individuals and businesses are not treated the same
Another important feature of the August Manual is the distinction between resident individuals and resident entities.
For resident individuals, the proposed framework permits certain externalisation of crypto assets through Authorised CASPs within the applicable foreign exchange allowance framework and subject to the requirements set out in the Manual.
The Manual's transaction examples show that where a resident individual transfers crypto from a South African custodial wallet to an offshore CASP or non-custodial wallet within the relevant framework, the transaction is treated as an export of capital and reported as an outward flow.
The position proposed for resident entities is different.
The Manual states that resident entities may open South African custodial wallets to purchase and sell crypto assets through Authorised CASPs, and that crypto assets held in those South African custodial wallets are deemed domestic.
However, the Manual also states that resident entities may not enter into crypto asset transactions deemed to be an import or export of capital under the Draft Regulations.
That distinction could have significant practical implications for South African businesses considering crypto assets as part of their international operations.
For example, businesses may need to consider carefully how the proposed framework could affect the use of crypto assets in cross-border payments, transfers or treasury arrangements.
The key point is that domestic ownership and trading of crypto by a resident entity are not presented in the Manual as equivalent to the externalisation of crypto by that entity.
The regulatory treatment changes when the transaction crosses into the proposed import/export framework.
What does this mean for CASPs?
The August Manual shifts some of the focus from whether a business can operate as a CASP to how its systems and processes handle cross-border activity.
An Authorised CASP facilitating transactions within the proposed framework would need to identify transactions that fall within the relevant cross-border categories, apply the applicable requirements and report the relevant transactions to FinSurv.
The Manual also contains detailed record-keeping requirements.
For relevant transactions, the information to be retained includes transaction identifiers, client and beneficiary information, crypto asset amounts, exchange rates, Rand equivalents, wallet identifiers and transaction hashes. The Manual proposes that records relating to transactions be retained for at least five years.
This means that the proposed framework has an important operational and systems dimension.
A CASP facilitating cross-border transactions would need to be able to identify the relevant transaction type, distinguish domestic from cross-border activity, capture the required information and support the necessary reporting.
That becomes particularly important where transactions involve non-custodial wallets, offshore service providers or complex transaction flows.
What remains uncertain?
The most important caveat is that this is still a draft framework.
The Draft Manual is currently open for public comment, with comments due by 30 September 2026. It also needs to be read alongside the Draft Capital Flow Management Regulations.
National Treasury and SARB have confirmed that comments received on the Regulations are still being considered and that the August Manual does not yet incorporate those submissions because of the timing and volume of comments. Both instruments remain subject to refinement following the consultation process.
The current proposal should therefore not be treated as the final legal position.
For businesses, however, the consultation period is still an important opportunity to understand the direction of travel and identify provisions that may have practical consequences for their business models.
The bigger picture
The August Draft Manual represents a shift in the conversation.
In April, the central question was whether crypto assets would be brought into South Africa's capital flow management framework.
The August Manual takes that one step further: it begins to answer the practical question of when a crypto transaction crosses the regulatory boundary.
And the answer is increasingly less about the label attached to the asset and more about the nature of the transaction.
Where is the value moving?
Who is involved?
Is the destination domestic or offshore?
Is the asset moving through an Authorised CASP or into a non-custodial wallet?
Does the transaction result in a cross-border inflow or outflow?
Those questions are becoming central to South Africa's emerging approach to crypto asset regulation.
The regulatory conversation is therefore shifting from:
“What is crypto?”
to:
“What is the transaction doing, where is value moving, and through whom?”
For crypto businesses and users operating across borders, that may ultimately be the more important question.