The Competition Commission has confirmed it received a formal complaint from Pretoria-based fintech Motswagae Holding, which has accused South Africa’s largest banks of blocking access to the ATM networks its cardless cash platform needs to operate.
In a statement last week, the little-known company said it had made a submission to the commission – it cited case number 2026Jul0016 – over what it called “structural access barriers” in the banking sector. The submission names FirstRand, Standard Bank, Capitec, Nedbank and Investec.
Commission spokesman Siyabulela Makunga told TechCentral he could “only confirm that the commission received a formal complaint” on 8 July. He did not comment on the merits of the complaint or say whether the commission would investigate.
According to Motswagae CEO Velly Sipho Phaloane, the complaint is directed not only at the five banks but also at the South African Reserve Bank (Sarb) and the Intergovernmental Fintech Working Group (IFWG).
At the centre of the dispute is 360Wallet, a platform Motswagae says would let consumers withdraw or deposit cash at any participating ATM using a voucher or e-wallet token, regardless of which bank issued it.
Today, someone who is sent money via a cardless voucher – a common way of reaching people without bank accounts – can typically only draw it at the issuing bank’s own ATMs or its selected retail partners. Motswagae claims its system would break down these silos and cut transaction costs for poorer and unbanked consumers.
What the sandbox letter says
The company says the platform is the subject of a South African patent application and that the IFWG’s regulatory sandbox – an initiative involving the Reserve Bank and other financial regulators that lets fintechs test ideas under supervision – determined on 30 June that 360Wallet falls within existing payments regulations and needs no regulatory exemptions to operate.
“The regulatory authorities have certified that our system is legally valid and requires no special legal exemptions to operate,” said Phaloane in the statement. “This clarifies that the barriers to entry facing financial inclusion innovations are not regulatory, but structural. When established financial infrastructure declines to interface with validated, lower-cost SMME utilities, it is the ordinary consumer who pays the price through inflated transactional fees.”
The sandbox letter, provided to TechCentral by Phaloane, tells a more complicated story. Dated 30 June, it informs Motswagae that its application to test 360Wallet “has been declined”. The sandbox only admits innovations that do not clearly fit existing rules, it explains, and “there does not appear to be a need for regulatory relief that could be assessed” here: 360Wallet “appears conceptually closer to activities that are already contemplated within existing regulatory frameworks” – referring to 2007 directives Motswagae’s statement cites. “Accordingly, the application is not suitable for further consideration,” it concludes.
Phaloane reads the outcome as vindication: if regulators see no need for regulatory relief, he argues, the barriers facing 360Wallet are commercial, not legal. In a general clarification, the Reserve Bank – answering also for the IFWG secretariat – partly supports that reading: the sandbox “is not a market-access mechanism”, it says, and rejection does not bar a product from market; where an innovation is found not to require regulatory relief, “this generally indicates that it is capable of operating within the existing regulatory framework”.
Even so, the letter stops well short of certifying 360Wallet as “legally valid”, as Phaloane’s statement puts it. Its language is expressly tentative – “appears”, “does not appear” – and it makes no finding on the model’s legality. Nor does being able to operate lawfully oblige any bank to connect to the platform, which is the commercial question at the heart of the complaint.
Reserve Bank pushes back
Beyond the commission’s confirmation that a complaint was received and the correspondence Phaloane has shared, the company’s claims could not be independently verified. Motswagae’s website was not operational at the time of publication. A complaint to the commission is an allegation by the complaining party; it does not mean the commission has found any wrongdoing, or even that it will investigate.
Motswagae’s statement also accuses the Reserve Bank of “centralised gatekeeping”, of ignoring proposals sent to governor Lesetja Kganyago and of responding through lawyers rather than engaging. The central bank rejected that characterisation outright – and gave a starkly different account of how the dispute turned legal.
“The Sarb does not accept the characterisation that it engages in ‘centralised gatekeeping’ or that it has declined to engage on this matter,” the Reserve Bank’s media office said in response to questions from TechCentral. “Mr Velly Sipho Phaloane of Motswagae Holding (Pty) Ltd issued a letter of demand containing spurious allegations against the Sarb, in which he threatened legal action. The Sarb will therefore not comment further pending a potential legal process.”
It also pushed back on the way the company connects the sandbox to its access complaint: the sandbox “does not address commercial access issues and therefore does not create any structural barriers nor prevent participation in the national payment system”, which is subject to a separate process, the bank said.
The Reserve Bank said it “continues to support the safe, efficient, competitive and inclusive development” of the payments system, “including through ongoing policy and regulatory reform work aimed at broadening access for qualifying non-bank participants”. It has in recent years moved to open the national payments system to fintechs, allowing non-banks to clear and settle payments without bank sponsorship.
The paper trail
TechCentral has seen Phaloane’s letter of demand, dated 24 June and addressed to Kganyago. It accuses the IFWG secretariat of “administrative malpractice” over sandbox delays and demands acknowledgement of a separate payments modernisation proposal submitted to the governor’s office on 30 April – failing which, it warns, Motswagae would seek a high court order and refer the Sarb to the commission as “a facilitator of market foreclosure”. In effect, that is what followed. The sandbox rejection arrived on 30 June; the Reserve Bank’s legal reply of 1 July denies all allegations and warns it will seek “a punitive legal cost order” if Phaloane litigates.
TechCentral has also seen a strategy document, dated 24 April, that Motswagae says accompanied its proposal. It describes 360Wallet as “production-ready” and pitches it as a modern successor to Saswitch, the decades-old interbank ATM switch, which was never built for cardless withdrawals. The document also shows Phaloane regarded the sandbox as “gatekeeping that disproportionately protects incumbent banks’ market position” in April – two months before his application was declined – and had resolved to commercialise the platform through routes that do “not depend on IFWG sandbox approval”.
Phaloane also points to timing: in June, after his proposal, the Reserve Bank published its “Towards a Cash Smart Society” position paper, which supports white-label ATMs – cash machines operated by parties other than the big banks. He contends his “proprietary strategic models were used to inform these regulatory and institutional directions behind closed doors”.
The paper does propose a white-label ATM framework. But TechCentral has seen no evidence of any link to Motswagae’s proposal – and the company’s own strategy document builds its case on Reserve Bank policy papers published before that proposal, from a March 2025 interoperability consultation to the February 2026 “Vision 2030+” paper.
Motswagae’s complaint comes in the middle of a broader industry debate about who gets access to South Africa’s payments infrastructure. The Reserve Bank’s payments modernisation programme envisages a national payments utility built on open, interoperable infrastructure, partly because cash remains stubbornly dominant and costs the economy an estimated R30-billion/year.
The industry’s flagship interoperability project, PayShap, has signed up millions of users but has been held back by fees and patchy bank implementations, and has since shifted its focus to merchant payments.
Phaloane says Motswagae remains “deeply committed to collaborating with all progressive banking partners, retail networks and regulators who share the national objective of modernising our payment systems and driving genuine mass economic inclusion”. – © 2026 NewsCentral Media
