Pension Funds Amendment Act No. 31 of 2024 and Section 37D Deductions

J Law Consulting (Pty) Ltd — 10 July 2025  |  JLAW IC 3 of 2025

The Pension Funds Amendment Act No. 31 of 2024 (PFAA) was promulgated in Government Gazette No. 50968 on 23 July 2024. It introduces changes to the Pension Funds Act and to specific public sector fund legislation necessary for the implementation of the two-pot retirement system with effect from 1 September 2024. The PFAA applies to all funds registered under the Pension Funds Act and to the funds established under the Post and Telecommunications-related Matters Act No. 44 of 1958 (Post Office Retirement Fund), the Transnet Pension Fund Act No. 62 of 1990 (Transport Pension Fund, Transnet Retirement Fund, Transnet Second Defined Benefit Fund), and the Government Employees Pension Law, 1996 (GEPF). The future maintenance provisions also apply to beneficiary funds.

1. Alignment of Definitions

The PFAA inserted a definition for "Income Tax Act" and introduced the following definitions into the Pension Funds Act, each cross-referenced to the corresponding definition in the Revenue Laws Amendment Act No. 12 of 2024: "member's interest in the retirement component", "member's interest in the savings component", "member's interest in the vested component", "retirement component", "savings component", "savings withdrawal benefit", and "vested component".

2. Accounting for Savings Withdrawal Benefit

Section 14B of the Pension Funds Act deals with the determination of a member's individual account and minimum individual reserve. The PFAA amended the formula for defined contribution funds by specifically adding a savings withdrawal benefit as a permissible debit under the "OC" (other credits and debits) element. For defined benefit funds, a new subparagraph (iii) was added to reduce pensionable service — or the minimum amount payable based on member contributions — to account for any savings withdrawal benefits already paid to the member.

3. Section 37A — Arrear Tax Deductions

Before the PFAA, section 37A of the Pension Funds Act allowed for a reduction of a member's benefit only in terms of the Pension Funds Act itself, the Income Tax Act, and the Maintenance Act. This meant that arrear taxes collectible under the Tax Administration Act No. 20 of 2011 — through an IT88L issued under section 179(1) of that Act — were not permitted as deductions from a fund benefit, because the Tax Administration Act was not included in the list of enabling Acts.

The PFAA amended section 37A to include the reduction of a benefit in terms of the Tax Administration Act, and made the same addition to the introductory paragraph of section 37D(1)(a). Arrear taxes may now be deducted from a member's fund benefit.

4. Section 37D Deductions — Order of Preference

Section 37D allows the following deductions from a member's benefit, in order of preference:

  1. (a) Tax payable on the benefit in accordance with the Income Tax Act — being the tax on lump sums under the retirement fund lump sum benefit and withdrawal benefit tax tables, and the marginal rate tax payable on a savings withdrawal benefit.
  2. (b) Housing loan or guarantee provided by the fund, where it was granted before any divorce or maintenance order giving rise to a deduction under section 37D.
  3. (c) Maintenance and interim maintenance order amounts, plus the tax payable on such deductions.
  4. (d) Divorce order amounts — the portion of pension interest assigned to a non-member spouse.
  5. (e) Compensation for damages caused by the member to their employer in respect of theft, dishonesty, fraud or misconduct, where the member has either admitted liability in writing or a judgment has been obtained against them in a court.
  6. (f) Amounts paid at the request of the member or beneficiary in respect of medical scheme contributions, insurance premiums, or any purpose approved by the FSCA (application fee: R1,856.00 from 1 October 2024 per FSCA General Notice 1 of 2024).
  7. (g) Arrear or outstanding taxes owed to SARS, deducted under an IT88L issued under the Tax Administration Act. IT88L is not attached to a directive where the reason is death, transfer, or security of mortgage bond/housing loan.

Section 37D(1B) limits the aggregate of all deductions to the value of the member's individual account or minimum individual reserve.

5. Housing Loans and Guarantees

Section 19(5) — permitted purposes

A fund may provide a direct housing loan or guarantee to a member only where the loan is used to settle an existing housing loan, purchase a house or stand, or make additions or alterations to a house. The property must be owned by the member and/or their spouse and must be occupied by the member or their dependant.

PFAA changes to the 65% cap

The PFAA aligns section 19(5)(c) with Regulation 28 (as amended from 3 January 2023), confirming that a housing loan or guarantee may not exceed 65% of the member's individual account or minimum individual reserve in the savings, retirement and vested components combined. Paragraph (d), which previously allowed a fund to increase the threshold to 100% in certain circumstances, is deleted. The 65% threshold is applied to the net housing loan amount (net of income tax).

Employer housing loans removed

Before 1 September 2024, section 37D(1)(b)(i) allowed a fund to deduct housing loans or guarantees provided by an employer. The PFAA removes this deduction. A fund may not deduct an amount payable to an employer in respect of a housing loan or guarantee provided by that employer. Housing loans for which the fund itself acted as guarantor continue to qualify as a permitted deduction under section 37D(1)(a)(ii).

Restrictions on housing loans

  • A fund may not grant a housing loan or guarantee if it has received notice and proof that divorce proceedings have been instituted, unless the non-member spouse's consent is obtained [section 37D(3)(aA)].
  • A fund may only allow a member to take a savings withdrawal benefit if sufficient funds will remain to repay the outstanding loan or guarantee.

6. Maintenance

Interim maintenance orders — section 37D(1)(d)(iB)

The PFAA introduces the deduction of amounts awarded to a maintenance claimant under an interim maintenance order granted by a court under rule 43 of the High Court rules or rule 58 of the Magistrates' Court rules. These orders apply from the date of grant until a divorce is finalised, at which point they are replaced by the divorce order.

Future maintenance — section 37D(3)(aC)

Prior to 1 September 2024, there was doubt about whether future maintenance could be deducted from a fund benefit without establishing mala fides on the member's part. Following Mngadi v Beacon Sweets [2003] and Sentinel Retirement Fund v Mtambo [2015], the position was uncertain. The PFAA resolves this: a fund may now give effect to a deduction of future maintenance from a member's individual account or minimum individual reserve without having to investigate the member's intent. Arrear maintenance must be paid as a lump sum. Future maintenance may be paid in monthly instalments directly to the claimant or as a lump sum to a beneficiary fund, which then deals with monthly payments to the claimant. There is currently no guidance on how the beneficiary fund should administer such payments.

Additional maintenance provisions

  • Section 37D(1A): A maintenance deduction may be made from the capital value of an in-fund pensioner's pension after retirement.
  • Section 37D(3)(aD): Where a maintenance order against the fund is in place, a savings withdrawal benefit may only be paid if sufficient funds will remain to comply with the order.
  • Section 37D(3)(aE): If the fund has received a formal written notice from a maintenance investigating officer to suspend a savings withdrawal benefit, it must suspend such benefit if the withdrawal would leave insufficient funds to comply with the pending order once granted.

The prohibitions in sections 37D(3)(aD) and (aE) apply only to savings withdrawal benefits. A pre-retirement withdrawal from a preservation fund's vested component cannot be suspended on this basis.

Requirements for a valid maintenance order

  • The order must have been issued by a South African court.
  • The fund must be named in or identifiable from the order.
  • The exact amount to be deducted must be specified.
  • The order must be one contemplated in section 37D(1)(d)(iA) or (iB) of the Pension Funds Act.

7. Divorce Orders

New definition of "pension interest"

The PFAA introduces a single definition of "pension interest" into the Pension Funds Act that applies across all fund types. It is defined as the member's individual account or minimum individual reserve, as the case may be, determined in accordance with the fund's rules on the date of the court order — in other words, the member's benefit in the fund on the date of divorce. This definition also applies to court orders made in respect of the division of assets in a religious marriage (for example, a Muslim marriage). In the event of a conflict between the Pension Funds Act and the Divorce Act, the Pension Funds Act prevails [new section 2(6)].

Interplay with the Divorce Act — retirement annuity funds

Where a divorce order refers to pension interest as defined in the Divorce Act, a retirement annuity fund must do two calculations: first, calculate the member's pension interest under the Divorce Act definition (contributions plus simple interest at repo + 3.5%) to establish what the non-member spouse is entitled to; second, calculate the member's pension interest under the Pension Funds Act definition (the individual account/minimum individual reserve) to establish the maximum the fund may deduct. The fund may not deduct more than the lesser of the two results.

Savings withdrawal benefit prohibition

Section 37D(aA) prohibits a fund from allowing a member to take a savings withdrawal benefit where the fund has received written notice from either party that divorce proceedings have been instituted that will result in a division of the member's pension interest, unless the non-member spouse's consent has been obtained. This prohibition remains until the proceedings are finalised or a court order is issued.

Requirements for a binding divorce order

  • The fund must be named in or identifiable from the order.
  • The order must specify the percentage of the member's pension interest or the exact amount assigned to the non-member spouse. References to "provident interest", "pension benefit", "joint estate", "interest in the fund", "policy proceeds", or "maturity value" will not be binding on the fund.
  • The fund must be specifically ordered to pay the assigned amount to the non-member spouse.

An order that does not meet these requirements remains valid but is not enforceable against the fund. It cannot be rectified by agreement between the parties — an amended court order is required.

Non-member spouse's options

The non-member spouse may have the assigned amount paid to them directly (taxed as a resignation benefit in their hands), or request that it be transferred to an approved retirement fund on their behalf (tax-free on transfer). Any pension interest deduction must be done proportionately across all three components.

8. Damages Due to Employer

PFAA changes to section 37D(1)(b)

  • References to employer-provided housing loans and guarantees are deleted.
  • A deduction may now be made on the date on which the member's employment with a participating employer is terminated, in addition to the previous triggers of retirement date and date of ceasing to be a member of the fund.
  • A savings withdrawal benefit may only be paid if doing so will leave sufficient funds to give effect to a written admission of liability or court order.
  • A savings withdrawal benefit must be suspended for up to one year pending a judgement in favour of an employer-deduction, if paying the benefit would leave insufficient funds to comply with the pending order.

Requirements for a valid employer deduction

  • There must be an amount due to the employer for compensation in respect of damage caused by the member.
  • The damage must have been caused by theft, dishonesty, fraud, or misconduct — interpreted restrictively to mean wilful, reckless and intentional conduct; negligent misconduct is excluded.
  • The member must have admitted liability in writing, or a judgment must have been obtained against them in a court (including a magistrate's court). A compensation order under section 300 of the Criminal Procedure Act No. 51 of 1977 also qualifies. A guilty plea in a criminal trial may constitute a valid admission (confirmed in Nyathi South Africa (Pty) Ltd v Mngomezulu PFA39/2024).
  • The written admission must be clear and unambiguous, made voluntarily, explain the circumstances giving rise to the loss, and be signed by the member. A mere tick-box selection of "theft, fraud, misconduct or dishonesty" is insufficient (confirmed in Edward Snell & Co Pty Ltd v Rahlao PFA71/2024, 29 April 2025).

Section 37D(1)(b) does not apply to retail funds (preservation funds and retirement annuity funds), as there is no employer participating in those funds. It applies to occupational funds only.

The fund has the right to withhold payment of a member's benefit pending finalisation of an employer's damages claim, but only after applying the audi alteram partem rule and balancing the member's and employer's competing interests (Highveld Steel and Vanadium Corporation Ltd v Oosthuizen [2008] ZASCA 164).

Published by J Law Consulting (Pty) Ltd

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