Mandated Investments & B-BBEE Ownership
Did you know that black people own shares in your company, indirectly, through their savings?
The people who work for companies that provide a pension fund as part of their salary package, and the people who provide for their own retirement through a retirement annuity, are all members of pension funds. There are millions of them in South Africa — and many of them are invested in your company through those funds.
Alternative Prosperity’s Mandated Investment analysis finds the participation by these people, measures it defensibly and conservatively, and reports it in a manner your verification agency will accept.
2011Research programme launched with the JSE & ASISA
3Disciplines on every engagement: actuarial, legal, financial services
Codes-alignedMethodology maps directly to FS100 / the Financial Sector Code
The mandated investment universe
Pension Funds · Unit Trusts · Insurers
There are many categories of mandated investment. These three are by far the biggest — which is why we focus on them.
Scale of participation
45 million+
Policies and fund memberships through which South Africans participate in mandated investment schemes
With flow-through analysis
Measured, evidenced, reportable
Delivered as an Independent Competent Person’s Report
Who Invests
Why It Matters
The Challenge
Our Track Record
How It Works
The Service
Get Started
Who Invests
Three ordinary savings decisions. One very large shareholder.
Most of the black economic participation in a listed company is not held by a name on the register. It is held by millions of individual South Africans, through the everyday products they use to provide for their retirement, their children and their families.
Pension funds and retirement annuities
People who work for companies that provide them with a pension fund as part of their salary package, and people who provide for their retirement through a retirement annuity, are all members of pension funds.
There are millions of pension fund members in South Africa, and many of them invest indirectly in your company through their funds.
Unit trusts
Millions of South Africans invest through unit trusts. Very often those investments exist for a specific human reason — saving for a child’s education, building a deposit, or putting something aside for later life.
Through those unit trusts, these savers invest indirectly in your company.
Insurance policies
People invest through insurance policies in two ways. They either cover themselves against calamity — life, disability and funeral cover — or they save through what are known as unit-linked policies.
Whichever route they use, these too are people who are invested in your company.
45 million+
Policies and instances of participation in mandated investment schemes across the South African market.
Mandated investment is by far the single biggest source of broad-based ownership of the South African economy.
It is also the least measured. In most listed companies, the participation of these savers has simply never been counted.
Why It Matters
Behind every one of those holdings is a household
The funeral policy holder in Khayelitsha, the school teacher contributing to her pension fund in Limpopo, the young professional building a unit trust portfolio in Sandton — they are all part of the same ecosystem, and all of them are invested in South Africa’s listed companies.
18.6 million
Retirement fund members, pensioners and beneficiaries in South Africa
FSCA Registrar of Pension Funds Annual Report (2023)
46.2 million
Risk and savings policies managed by ASISA member life insurers
ASISA Long-Term Insurance Statistics (December 2025)
R3.87 trillion
Held in 1 878 local collective investment scheme portfolios — roughly half of South Africa’s GDP
ASISA CIS Industry Statistics (March 2025)
R639 billion
Paid to policyholders and beneficiaries in claims and benefits in 2024 — the highest single year on record
ASISA Long-Term Insurance Statistics (2025)
“Ownership, for B-BBEE purposes, is not only what is held directly and self-evidently by black South Africans — it is also what is held on their behalf, indirectly, through retirement funds, insurance policies and unit trusts. Mandated investment is the mechanism that surfaces and quantifies that indirect ownership.”
Trevor Chandler — Chairman, Alternative Prosperity Holdings. Former Chairperson of the Financial Sector Transformation Council Board and former Senior Policy Advisor to ASISA. From The Quiet Revolution, Part 1.
The Challenge
Financial intermediation was never built for measuring transformation
Modern capital markets move fast and largely anonymously. That’s efficient for trading — but it means a huge share of black economic participation by individuals in listed companies simply disappears from view.
01
Mandated investments are enormous
Pension funds, collective investment schemes and long-term insurers collectively hold a substantial share of every JSE-listed company’s register — often larger than any single identifiable shareholder.
02
Are you missing the impact you are already making?
As a listed company, you are one of the mechanisms through which millions of South Africans participate in wealth creation — their retirement, their children’s education, their family’s security. Without a mandated investment analysis, that contribution is never quantified, and never told.
03
Doing it properly takes specialist skill
Flow-through measurement needs actuarial technique, financial-services domain knowledge, legal interpretation of the Codes, and the data-matching capability to trace beneficiaries through funds, schemes and policies.
Our Track Record
We didn’t build this methodology for a brochure. We built it for a national policy question.
Alternative Prosperity’s mandated investment work began as public-interest research, not a product pitch — which is exactly why regulators, verification agencies and listed companies rely on it today.
Our multidisciplinary team spans B-BBEE ownership specialists, financial-services and actuarial expertise, legal interpretation of the Codes, and the data engineering needed to trace ownership through complex fund structures — assembled specifically so every conclusion can withstand verification-agency scrutiny.
Circa 2011
A public-interest question, answered with rigour
Appointed and funded by the JSE, with the support of ASISA, to answer a simple but consequential question: to what extent do black people actually own shares on the JSE?
2011 to 2017
Peer-reviewed, audited, and published
The resulting methodology was peer-reviewed by National Treasury and audited by independent verification agencies, with findings published widely and presented to Parliament as part of the national “Ownership Monitor” research.
Ongoing
A standing capability, not a one-off study
What started as research is now a repeatable service: Independent Competent Person’s Reports, prepared to the standard verification agencies expect, for companies who want their real ownership picture reflected.
How It Works
One integrated process, from raw fund data to a defensible report
Our mandated investment process is a single pipeline — not a black box. Each stage feeds the next, and every conclusion can be traced back to its source data.
1
Data Collection
Public, semi-public and client / project-level data on the underlying investment and its investors.
2
Data Analysis
Identification of mandated investments and application of the relevant measurement methodology.
3
Register Analysis
Voting rights and economic interest measured for black people, black women and black youth, on a flow-through basis.
4
Related Services
Corporate finance, B-BBEE committee support, compliance-committee support and scorecard solutions where needed.
5
Communicate
Report production, data aggregation and presentation to your verification agency for inclusion in your certificate.
Three principles that keep every finding defensible
Conservative by default
Where the B-BBEE status of a beneficiary cannot be determined, it is treated as non-black. Nothing is ever inflated to reach a better number.
Proportionate value basis
Economic interest is measured on proportionate value, not headcount — because the Codes measure economic participation, not the number of people involved.
Vested rights only
Only vested rights are taken into account when calculating a member’s proportionate share, so every figure reflects an actual, current entitlement.
Where the analysis focuses
Pension funds
Employer-sponsored pension and provident funds, umbrella funds and retirement annuities — the savings of millions of working South Africans.
Unit trusts
Collective investment schemes held directly or through linked-investment platforms, including savings earmarked for education and long-term family goals.
Insurance companies
The policyholder funds standing behind life, disability and funeral cover, and behind unit-linked savings policies.
There are many categories of mandated investment. Pension funds, unit trusts and insurance companies are by far the biggest — which is why the analysis concentrates there. Other categories are considered where they are material to a particular register.
The Service
An Independent Competent Person’s Report your verification agency already recognises
The Codes are specific: mandated investments as defined in Paragraph 3.7.3 of Code Series 100, Statement 100, can only be counted as black-owned if a qualified Competent Person estimates the extent of that ownership. We are that Competent Person.
Every engagement is built around your actual share register and your actual mandated investors — not generic assumptions — and delivered as a formal, citable report ready to hand to your verification agency.
Getting Started
From register to report in four stages
Scoping conversation
We review your current B-BBEE ownership position and identify where mandated investment exposure sits in your register.
Data & register access
You provide share register and underlying investor data; we handle it under strict confidentiality throughout.
Flow-through analysis
Our team applies the measurement methodology to determine black economic interest and voting rights on a flow-through basis.
Report & sign-off
You receive a signed Independent Competent Person’s Report, ready for your verification agency’s review.
Who It’s For
Built for the people who own the B-BBEE scorecard
JSE-listed companies
Issuers whose share registers include significant pension fund, unit trust and insurance ownership that has never been formally measured.
Transformation & compliance teams
B-BBEE and DE&I officers who need a defensible, Codes-aligned basis for the ownership element of their scorecard.
CFOs & company secretariats
Finance and governance leaders preparing for verification-agency review who want the analysis right the first time.
Illustrative Insights
What a flow-through analysis actually surfaces
Every register is different — these views illustrate the kind of picture our methodology produces once mandated investments are properly analysed.
Illustrative mandated investment category split
Indicative structure only — every engagement is measured against your own registerPension funds
Collective investment schemes
Long-term insurers
Other mandated categories
Confidentiality & Governance
Every register we touch is treated as strictly confidential
Our reports carry real regulatory weight precisely because we handle underlying data — yours and your investors’ — with the same discretion we’d expect of our own.
Private & confidential by default
Every report is prepared exclusively for the requesting entity and is not published or shared without explicit permission.
Independence, checked
Every engagement is reviewed to confirm no member of the team holds a material interest that could impede independence.
Verification-agency ready
Findings are formatted and referenced against the Codes so they can be presented directly to your verification agency.
Traceable methodology
Every figure can be traced back to its underlying data source and the specific measurement principle applied to it.
The Difference It Makes
From an assumed zero to a measured, evidenced number
Without a Mandated Investment analysis
- –The participation of millions of savers in your company is never measured
- –Real, existing black economic participation goes unrecorded on the scorecard
- –No documented basis for the ownership position you report
- –Your role in broad-based wealth creation stays invisible to stakeholders
With an Alternative Prosperity ICPR
- ✓Black voting rights and economic interest measured on a flow-through basis
- ✓Findings backed by a Codes-aligned, peer-reviewed methodology
- ✓A signed report your verification agency can rely on directly
- ✓An accurate, defensible reflection of your true ownership position
Find out what your register is really telling you.
Book a confidential scoping conversation with our Mandated Investment team — no pricing, no obligation, just a clear view of where you stand.