For established organisations, B-BBEE is rarely something that begins a few weeks before verification.
Procurement teams have supplier strategies. HR teams run skills development programmes. Transformation teams manage enterprise and supplier development initiatives. Finance teams track expenditure. Management monitors the organisation’s broader transformation objectives.
In many businesses, these processes have been refined over years.
So the question is not necessarily:
“Are we doing anything?”
The more useful question may be:
“Can we demonstrate what our B-BBEE initiatives actually achieved?”
That distinction is becoming increasingly important.
The 2026 draft amendments to the B-BBEE Codes proposed changes that would place greater emphasis on needs analysis, performance metrics, outputs and outcomes, and annual monitoring and evaluation in relation to ESD contributions. The proposed framework remains subject to the legislative and policy process, so these provisions should not be treated as current requirements. However, they provide an important indication of the direction of policy thinking.
For established businesses, that is worth paying attention to.
From “What Did We Spend?” to “What Did It Change?”
One of the easiest ways to manage B-BBEE is to think in terms of transactions.
We contributed this amount.
We supported this beneficiary.
We funded this programme.
We purchased from these suppliers.
We trained these employees.
These are important records, but they do not necessarily tell the whole story. Consider an enterprise development initiative. A business may provide funding, mentorship, equipment, or professional services to a black-owned business. The intervention has taken place, but a more strategic approach asks:
What was the business trying to change through that intervention?
Was the beneficiary struggling with access to finance?
Was it unable to meet a particular procurement requirement?
Did it lack systems or skills?
Was it capable of taking on larger contracts but lacked the capacity to do so?
If the underlying need is not clearly understood, the intervention may be well-intentioned but poorly targeted.
This is why the proposed emphasis on needs analysis is significant. It moves the conversation closer to why the intervention exists in the first place.
An Initiative Can Be Successful for B-BBEE and Still Underperform for the Beneficiary
This is perhaps one of the more uncomfortable questions businesses should be asking. Imagine that an organisation has supported the same beneficiary for several years.
The contribution is properly recorded.
The required documentation is available.
The programme has been implemented.
From an administrative perspective, everything appears to be in order. But the beneficiary’s business has remained stagnant. Turnover has not meaningfully improved. The business has not secured new markets. Employment has not increased. Operational capacity has not materially changed.
At what point should the organisation ask whether continuing the same intervention is actually the best use of its transformation investment?
This doesn’t mean the initiative was necessarily unsuccessful. It means the business should be prepared to review whether the intervention is still solving the problem it was designed to solve.
That is a very different way of thinking about ESD.
The Best Beneficiary May Not Be the Most Convenient Beneficiary
Established businesses often develop relationships with beneficiaries over time. That continuity can be valuable. But familiarity should not replace strategic assessment. A beneficiary that was the right fit three years ago may have:
- outgrown the original intervention;
- developed different needs;
- reached a point where additional support should take a different form;
- or no longer align with the measured entity’s transformation objectives.
Conversely, a newer beneficiary may have a more significant development gap and greater potential for measurable growth. The question should therefore not simply be:
“Who can we support?”
It should be:
“Where can our intervention create meaningful and sustainable value?”
That is a much more strategic question.
Measure the Intervention — Not Just the Expenditure
The proposed amendments are particularly interesting because they refer to performance metrics and outcomes such as turnover growth, job creation, increased access to markets, increased profitability and greater innovation.
Businesses should take note of the broader principle behind this. If an organisation wants to understand whether its ESD strategy is working, it needs some way of assessing change. That doesn’t necessarily mean every initiative will produce immediate revenue growth. Different interventions have different objectives.
For example:
| Intervention | Possible objective | Possible indicator |
| Financial support | Improve business capacity | Investment in productive assets / working capital capacity |
| Market access | Create new commercial opportunities | New contracts or customers |
| Mentorship | Strengthen business capability | Implementation of improved systems/processes |
| Skills development | Build internal capability | Skills acquired and applied |
| Technology support | Improve operational efficiency | Increased capacity or reduced process constraints |
The important point is not to create arbitrary measurements simply because a verification process may require them. The measurement should make sense for the intervention itself.
Your Documentation Should Tell a Story
This is where technical B-BBEE preparation becomes particularly important. A collection of invoices, agreements, reports and payment records may demonstrate that activities took place, but stronger documentation should allow an independent reviewer to understand:
Why was this intervention selected?
↓
What need was identified?
↓
What support was provided?
↓
What was the intended outcome?
↓
How was progress monitored?
↓
What changed?
That sequence creates a much clearer evidentiary trail. This is also more useful to the business itself—not just the verification agency.
The Verification File Shouldn’t Be the First Time You Ask These Questions
One of the biggest strategic mistakes is treating verification preparation as a documentation exercise that happens at the end of the measurement period. By then, it may be too late to correct weaknesses in an initiative.
If a business discovers during verification that:
- the original objective was unclear;
- beneficiary needs were never documented;
- progress was never measured;
- agreements were incomplete;
- or the supporting evidence doesn’t demonstrate the intended outcome,
the organisation may have very limited room to fix the underlying issue.
That is why verification readiness should begin much earlier. Not because businesses need to spend the entire year preparing files. But because good evidence begins with good programme design.
Does This Mean You Should Abandon Your Existing B-BBEE Initiatives?
No.
This is an important distinction.
The proposed amendments are not yet final, and businesses should not make major strategic decisions solely on the basis of draft provisions, but businesses can use this moment to ask whether their existing programmes are still producing the outcomes they were intended to produce.
Some initiatives may be working extremely well. Others may simply have become part of the annual B-BBEE routine. And there is a difference.
The question isn’t:
“Can we still claim this?”
It should increasingly be:
“Is this still the right intervention for the business and the beneficiary?”
That shift in thinking can improve transformation strategy even before any proposed regulatory changes take effect.
Three Questions for Your Next ESD Review
Before simply renewing an existing initiative, ask:
1. What business need are we addressing?
If the answer is unclear, the intervention may need to be reassessed.
2. What would meaningful progress look like?
The answer should be appropriate to the beneficiary and the type of support being provided.
3. Can we demonstrate the journey?
Not simply that money was spent, but that the intervention was planned, implemented, monitored, and assessed.
These questions can help businesses move from activity management to outcome management.
The Opportunity for Established Businesses
The evolution of B-BBEE should not necessarily be viewed only as another compliance burden.
It can also be an opportunity to examine whether transformation expenditure is producing value.
For an established organisation, a stronger ESD strategy can potentially achieve several objectives at once:
- strengthen emerging suppliers;
- create more resilient supply chains;
- develop future procurement partners;
- support sustainable black-owned businesses;
- improve internal transformation outcomes;
- and create a clearer evidence base for verification.
That is considerably more valuable than simply completing another annual compliance exercise.
What Should Your Business Do Now?
The proposed 2026 amendments remain subject to the regulatory process, and businesses should distinguish between what is currently required and what may become required.
However, this does not mean there is nothing to do. Established organisations can begin by reviewing their current ESD and transformation programmes and asking:
Are our beneficiaries still the right beneficiaries?
Are we addressing defined business needs?
Are we measuring meaningful progress?
Can we demonstrate the rationale behind our interventions?
Does our documentation capture more than expenditure?
Would we be able to explain the impact of our initiatives to an independent reviewer?
If the answers reveal gaps, that is useful information. It gives the organisation an opportunity to improve its approach before those gaps become a verification problem.
B-BBEE Strategy Requires More Than a Certificate
The direction of the B-BBEE conversation is increasingly concerned with the effectiveness of transformation—not simply the existence of transformation activities.
Government has itself described the review as an effort to strengthen implementation and address gaps, including concerns around the effectiveness of ESD in helping established entities assist and grow black enterprises and SMMEs.
For established businesses, this means the technical side of B-BBEE is becoming increasingly important.
It is not enough to know what the scorecard says.
Businesses also need to understand how their activities, beneficiaries, evidence, and commercial objectives connect.
That is where technical B-BBEE expertise can make a difference.
At Azania BEE, we support organisations with B-BBEE verification and technical guidance to help them understand their requirements, identify potential gaps and approach verification with greater confidence.
If you’re questioning whether your current ESD initiatives are still fit for purpose, whether your evidence adequately supports your activities, or how your B-BBEE approach should evolve as the framework develops, speak to Azania BEE.
The objective isn’t simply to prove that something happened.
