IMPACT – MEDIUM

What is the change?  A recent decision of the Department of Home Affairs to prohibit asylum seekers from applying for temporary or permanent residence status while in South Africa faces a legal challenge. The DHA is expected to defend the court action, which is scheduled for an April 21 hearing.

What does the change mean? Pending the outcome, employers should be aware that foreign nationals applying for asylum in South Africa continue to be work authorized but must be immediately terminated if their applications are refused and they no longer have the option to apply for work permits while in South Africa.

  • Implementation time frame: Immediate.
  • Who is affected:Companies employing asylum seekers in South Africa; foreign nationals in South Africa with outstanding asylum applications.
  • Business impact: If an employee’s asylum application is refused, the employment must be terminated and any subsequent work permit application must be submitted overseas.
  • Next steps:Employers should review the immigration status of their South African workforce to determine the level of risk exposure. BAL can assist in the process.  

Background: The number of employers impacted by the recent change in DHA policy is potentially significant, given that an estimated 10 percent of the South African workforce are foreign nationals with outstanding asylum applications. Nearly 870,000 new asylum applications were submitted to the DHA between 2008 and 2013.

Under a 2008 court order, the DHA allowed asylum seekers to apply for temporary or permanent residence permits without risk to an outstanding asylum application. Under a recent policy change, however, the DHA no longer allows asylum seekers to change immigration status in-country, requiring them to return home to apply for a temporary or permanent residence permit. The change effectively forces them to give up their asylum claim before submitting an application for temporary or permanent residence. The policy became effective Feb. 3 and applies to all outstanding applications regardless of the submission date.

BAL Analysis: As applications for temporary residence permits include applications for South African work permits, employers need to be aware that, although foreign nationals applying for asylum in South Africa continue to be work authorized, the employment of the foreign national must be immediately terminated if the DHA refuses that application. Employers should also be aware that, pending the outcome of the current legal challenge to the DHA policy, the foreign national can no longer apply for a work permit while in South Africa.

This alert has been provided by the BAL Global Practice group. For additional information, please contact your BAL attorney.

Copyright © 2016 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – MEDIUM

What is the change? South Africa has begun issuing multiple-entry visitor visas that are valid for up to three years to business travelers, tourists and academics.

What does the change mean? The new visas are not available to first-time applicants or nationals of visa exempt countries. However, the change will greatly benefit frequent travelers who require visitor visas to enter South Africa because the allowable extended validity period should significantly reduce the need for repeat visa applications.

  • Implementation time frame: Immediate and ongoing.
  • Visas/permits affected: Visitor visas.
  • Who is affected: Non-visa exempt nationalities who travel to South Africa.
  • Impact on processing times: The longer validity will significantly reduce the need for repeat visa applications for qualifying travelers.
  • Business impact: The issuance of visas with longer validity is intended, in part, to boost the attractiveness of South Africa as a destination for foreign direct investment.

Background: The change is part of South Africa’s continuing efforts to address criticism that strict visa rules have caused a decline in travel to the country.

The new visit visas will be valid for up to three years, but may be issued with shorter validity periods at the discretion of the South African mission issuing the visa. Visa holders will be permitted to stay in South Africa for up to 90 days on each visit for business, tourism or academic purposes. Work activities are not permitted on visitor visas, and work authorization is still required in this regard.

BAL Analysis: The change does not affect nationals of visa exempt countries. The longer-validity visas will make travel more convenient for foreign nationals who require a visa and who travel frequently to South Africa.

This alert has been provided by the BAL Global Practice group. For additional information, please contact your BAL attorney.

Copyright © 2016 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – MEDIUM

What is the change? A senior official of the Department of Home Affairs has been charged with corruption for allegedly accepting a police informant’s bribe to facilitate the processing of permits.

What does the change mean? Companies are reminded that corruption does exist and that cases processed unusually quickly and without reasonable explanation should be treated as suspicious and investigated.

  • Implementation time frame: Ongoing.
  • Visas/permits affected: All immigration matters.
  • Impact on processing times: It is anticipated that the arrest of the official will temporarily prolong the current seasonal extended processing times in South Africa because officials in the agency may now take longer to adjudicate applications when compared to average processing times before the holiday break.
  • Business impact: Companies should be mindful of the potential for corruption in any immigration process and be aware that the arrest of the senior official in South Africa may cause processing delays in the short term.

Background: The arrest is the latest in the Department of Home Affairs’ ongoing anti-corruption operation, Bvisa Masina (“throw out the rot”). Launched in April 2015, this initiative is generally considered to have been a success. According to a statement by the Home Affairs Minister, there have been more than 30 arrests to date and multiple officials have been given prison sentences for various crimes, such as selling fraudulent documents and manipulating permit procedures.

In the most recent case, a special unit of the South African police force, working in cooperation with an anti-corruption unit of the DHA, arrested the senior DHA official on Dec. 17. She was subsequently charged with accepting a police informant’s bribe of 40,000 rand (about US$2,600) in connection with the processing of permits and has been released on bail pending a criminal court appearance.

BAL Analysis: The arrests and other successes of the Bvisa Masina operation are evidence of the DHA’s commitment to tackle both perceived and actual corruption in South African immigration processes and that the necessary resources have already been devoted to the cause. Employers should note the DHA’s policy of zero tolerance and its stated intention to deal decisively with fraud and corruption. In addition, employers should be mindful that the seniority of the DHA official most recently arrested may impact all applications, in at least the short-term, as immigration officials may now be inclined to take longer to adjudicate cases and to interpret rules and procedures more conservatively in order to avoid any possible appearance of irregularity.

This alert has been provided by the BAL Global Practice group. For additional information, please contact your BAL attorney.

Copyright © 2016 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – MEDIUM

What is the change? VFS Global processing centers and other offices and agencies providing immigration services will close or limit operations for roughly two weeks during the Christmas and New Year holiday season.

What does the change mean? Services will be limited. Visa and work permit applications that are pending may be delayed by two weeks or more. Applicants should submit applications as soon as possible.

  • Implementation time frame: Roughly Dec. 22 through Jan. 3.
  • Visas/permits affected: All visas, permits and other immigration services.
  • Who is affected: South African and foreign nationals in need of immigration services from now until early January.
  • Impact on processing times: Processing times will be delayed due to the closures and resulting backlogs.
  • Business impact: Businesses may need to adjust timelines due to expected delays in visa and work permit processing.

Background: VFS Global processing centers in South Africa will be closed for submissions and appointments from Dec. 22 until Jan. 3. During some of that time, offices will remain open for collections between the hours of 8 a.m. and 3 p.m.

Date VFS Global Processing Center Holiday Schedule
Dec. 22-23 Closed for submissions; open for collections only.
Dec. 24-27 Offices closed.
Dec. 28-29 Closed for submissions; open for collections only.
Dec. 30-Jan. 3 Offices closed.
Jan. 4 Offices reopen for submissions and collections.

The South African Qualifications Authority will be closed from Dec. 23 until Jan. 4. During SAQA’s closure, qualifications evaluations for Critical Skills Work Visa and General Work Visa applications will be placed on hold. Most professional boards and councils will also be closed during the holidays, some as early as Dec. 18 until Jan. 4 or Jan. 11. These closures also affect qualifications evaluations for Critical Skills Work Visas. South African embassies and consulates will be closed to the public for varying periods between Dec. 24 and Jan. 4. Foreign embassies and consulates in South Africa will also be closed for varying periods between Dec. and Jan. 11.

BAL Analysis: Holiday closures will cause processing delays, so those in need of immigration services are advised to submit applications as early as possible. Those with questions about specific closures should contact the relevant office or agency or their local BAL professional.

This alert has been provided by the BAL Global Practice group and our network provider located in South Africa. For additional information, please contact your BAL attorney.

Copyright © 2016 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – MEDIUM

What is the change? South Africa’s diplomatic missions in New Delhi and Mumbai are facing increased workload and staffing shortages that have caused serious processing delays.

What does the change mean? Foreign nationals applying for work permits or visas at South African missions in New Delhi or Mumbai should submit their applications as soon as possible and anticipate delays.

  • Implementation time frame: Immediate and ongoing.
  • Visas/permits affected: All visas, permits and other immigration-related services.
  • Who is affected: Foreign nationals in need of immigration-related South African missions in New Delhi or Mumbai.
  • Impact on processing times: Processing times have increased across the board. Short-term visa applications are taking three weeks to process, as opposed to the standard five to seven business days. Work permits are also taking significantly longer than the standard 60 business days to process.
  • Business impact: Business travelers should submit visa applications as early as possible and build extra time into their schedules because of the delays in processing.
  • Next steps: BAL will continue to follow reports of delays at South Africa’s missions in India and will inform clients if processing times become significantly better or worse.

Background: The delays are due to a shortage in staffing and an increase in demand for visas, permits and other services. South African officials in India have reported that they are experiencing roughly double their normal workload. There is no indication at this point of when delays might be alleviated, but the backlogs are serious. More than 800 applications are pending in Mumbai, and officials this month were still busy with visa applications from June.

BAL Analysis: Travelers in need of immigration-related services at South African missions in India should submit applications as soon as possible to avoid unnecessary delays in their travel.

This alert has been provided by the BAL Global Practice group and our network provider located in South Africa. For additional information, please contact your BAL attorney.

Copyright © 2016 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – MEDIUM

What is the change? After a meeting of the Inter-Ministerial Committee on strict visa rules that have caused a decline in travel to the country, the Department of Home Affairs announced policies that will make it easier for visitors to apply for visas. Rules that children carry birth certificates will continue to be enforced, but with some easing of the rules for minors from visa-exempt countries.

What does the change mean? The department promises in the next three months to launch a pilot program to take biometrics at ports of entry for foreign visitors whose home country does not have a South African consular mission and to consider multiple-entry visas that will be valid for up to three years for frequent business travelers. The department will consider longer-range policies in the next year, including expansion of visa centers and consideration of longer-validity visas or visa waivers for China, India and Russia.

  • Implementation time frame: Ongoing.
  • Visas/permits affected: Business visas; documents required for traveling minors.
  • Who is affected: Business visitors; children traveling to or from South Africa.
  • Business impact: If implemented, the changes could ease short-term business travel and tourism. Note that there is no change to immigration regulations on long-term work visas.

Background: Last year, South Africa introduced strict rules on visas and traveling children. Visa applicants were required to appear in person at a South African consulate to give biometrics, making it especially difficult for foreign nationals from countries that do not have a South African mission to obtain visas. The rules on traveling minors required them to carry unabridged birth certificates or permission from their parents or guardians, or a divorce or death decree of parents where necessary.

The onerous rules have cause tourism to nosedive, leading to the meeting of the Inter-Ministerial Committee. Following that meeting, the Department of Home Affairs announced several changes:

Regarding in-person visa application rules, the DHA plans in the next three months to:

  • Start a pilot program to accept biometrics at three airports in South Africa.
  • Consider long-term multiple-entry visas for up to three years for frequent business travelers.
  • Consider an accreditation program for tourism companies in high-volume countries of China, India and Russia.

In the next year, DHS plans to:

  • Consider visa waivers for China, India, Russia and other countries.
  • Consider issuing visas on arrival for travelers who already hold a valid visa to Canada, the U.K. or the U.S.
  • Open two business visa facilitation centers in Durban and Port Elizabeth and add visa centers in Botswana, Zimbabwe and the United Arab Emirates.
  • Consider 10-year multiple-entry visas for certain frequent travelers for business.

Rules mandating that traveling minors carry unabridged birth certificates will remain in effect for outbound and inbound children, but will be eased for visa-waived children in place of a strong advisory for certain documentation.

  • Birth certificates will continue to be part of the visa application process for visa-required nationals.
  • For visa-waived nationals, a strong advisory will be issued that children should carry parental consent to travel and proof of their relationship.
  • The validity of parental affidavits will be extended to six months and letters from school principals will be issued and accepted for children traveling on school tours.

BAL Analysis: While the proposed measures may ease short-term business travel as well as travel for children from visa-waived countries, it is important to note that the DHA has not implemented the new measures, and the dates and details of implementation remain vague. Therefore, current rules remain in place.

This alert has been provided by the BAL Global Practice group and our network provider located in South Africa. For additional information, please contact your BAL attorney.

Copyright © 2016 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – MEDIUM

What is the change? Technical problems resulting from changes to appointment booking procedures at Visa Facilitation Services (VFS) centers have delayed visa applications.

What does the change mean? Those applying for visas at  VFS centers in South Africa should prepare for delays and may have to change travel plans.

  • Implementation time frame: Ongoing.
  • Visas/permits affected: All visas handled at VFS centers.
  • Who is affected: Foreign nationals applying for visas at VFS centers in South Africa.
  • Impact on processing times: Some applicants have not been able to file applications due to technical problems at the VFS centers. Delays in processing should be expected.
  • Business impact: Businesses may have to alter travel plans or anticipated start dates due to the delays.

Background: VFS centers in South Africa are in the midst of a changeover to a new appointment booking system that requires payments in advance. The change has led to technical difficulties over the past two weeks. The South African government has not issued any official information about the difficulties, but the problems have made it impossible to submit applications in some instances.

BAL Analysis: BAL will continue monitoring the technical problems and update clients on any significant developments.

This alert has been provided by the BAL Global Practice group and our network provider located in South Africa. For additional information, please contact your BAL attorney.

Copyright © 2016 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – MEDIUM

What is the change? South Africa’s Department of Home Affairs has issued new guidelines on its requirement that minors travel with an unabridged birth certificate and other relevant documents.

What does the change mean? The new guidelines provide exemptions to the rule for minors with valid South African visas; minors who entered South Africa before June 1; minors in direct transit at an international airport; and minors traveling with parents from countries such as India, where parents’ particulars are endorsed in the child’s passport. However, because of ongoing confusion over enforcement of the new rule, adults traveling with minors should be prepared to produce an unabridged birth certificate if possible even if an exemption applies.

  • Implementation time frame: The guidelines were posted to DHA’s website May 26, just days before the new requirement’s June 1 effective date. Discussions about the requirement and its implementation are ongoing.
  • Who is affected: Adults traveling with minors to or from South Africa.
  • Impact on processing times: Adults traveling with minors to or from South Africa should leave extra time to obtain documents and any necessary certifications or translations, even if an exemption applies to their situation.
  • Business impact: The new requirement has drawn fire from groups concerned about a negative effect on tourism and business in South Africa.
  • Next Steps: BAL will continue monitoring the implementation of the new requirement.

Background: The requirement that minors travel with unabridged birth certificates and other relevant documents is part of last year’s immigration overhaul and was initially postponed to give parents and government agencies sufficient time to prepare.

The requirement is intended to crack down on child trafficking and other illicit activities, but has been criticized by groups concerned about its impact on tourism and business in South Africa. It took effect June 1, however, days after DHA released guidelines outlining the exemptions described above. There is no set time limit on the exemption for minors who traveled to South Africa before June 1. However, minors who stay long enough in South Africa are required to obtain a visa, which requires an unabridged birth certificate. The length of time a minor can remain in South Africa without a visa depends on nationality.

For the time being, the South African government is relying largely on airlines to enforce the new requirement at the point of departure for South Africa. It is not clear that all parties responsible for enforcing the new requirement understand the rules and exemptions.

BAL Analysis: Due to possible confusion, BAL recommends that those traveling with minors be prepared to produce an unabridged birth certificate and other relevant documents even if an exemption applies. Otherwise, travelers who encounter airline officials or migration agents unfamiliar with the exemptions may face significant travel delays. BAL will continue to monitor the implementation of the new requirement, including any possible changes to the current rules or enforcement trends.

This alert has been provided by the BAL Global Practice group and our network provider located in South Africa. For additional information, please contact your BAL attorney.

Copyright © 2016 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – MEDIUM

What is the change? South Africa is allowing foreign nationals in all categories of Work Visas and Business Visas to study part-time without having to apply for separate permission to do so.

What does the change mean? The change makes it easier for foreign employees and assignees to pursue part-time college education in South Africa, as long as the university or college is registered under the appropriate government department.

  • Implementation time frame: Immediate.
  • Visas/permits affected: Work Visas (including Intracompany Transfers, Critical Skills Visas, and General Work Visas) and Business Visas (for foreign nationals who are self-employed).
  • Who is affected: Foreign nationals holding the above visas.
  • Impact on processing times: The rule reduces the need to apply for a separate endorsement to pursue studies.
  • Business impact: Foreign nationals in South Africa may more easily pursue coursework at a registered college or university on a part-time basis.

Background: The Department of Home Affairs has announced that effective retrospectively to May 1, it will automatically allow holders of Work Visas and Business Visas to pursue part-time study. The school must be established as a higher education institution under the Higher Education Act or as a college under the Department of Higher Education and Training. Study at other schools is not allowed.

BAL Analysis: Foreign nationals working in South Africa who wish to pursue studies should note that full-time study is not allowed and coursework is only allowed during the period when the Work Visa or Business Visa is valid.

This alert has been provided by the BAL Global Practice group and our network provider located in South Africa. For additional information, please contact your BAL attorney.

Copyright © 2016 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – MEDIUM

What is the change? South Africa has opened registration for companies who wish to use a new one-stop premium visa service center for faster visa and work permit renewals.

What does the change mean? Companies must apply in writing and undergo a selection process by the Department of Home Affairs based on a points system. 

  • Implementation time frame: Applications will be accepted beginning May 12. The cut-off date for submission of applications is 10 working days after May 12.
  • Visas/permits affected: Work visas and permit renewals.
  • Who is affected: Companiesemploying a large number of foreign workers.
  • Impact on processing times: The premium service aims to put in place a shorter, more efficient process for visa and permit renewals.
  • Business impact: Approved companies will benefit from streamlined visa renewal and other premium service, including access to immigration advisory services.
  • Next steps: Given the short application window, companies who wish to be considered for corporate account status should apply immediately. BAL can assist in the application process.

Background: The one-stop center will serve select corporate applicants who have been approved for Corporate Account status. Applications for this status must be made in writing within 10 working days of the Gazette notice of May 12. An advisory committee will select companies by awarding points based on the following criteria:

  1. Numbers of visas required in key positions over the coming three years, calculated in man-years (hours worked by an individual per year) (20 points).
  2. Amount of incremental capital expenditures over next three years (20 points).
  3. Relevance of requested visas to South Africa’s national development and infrastructure (20 points).
  4. Percentage of visas that are for critical skills (20 points).
  5. Efforts by the company to transfer skills to South African workers (20 points).
  6. Proof that at least 60 percent of the company’s local workforce are South Africans or permanent residents employed in permanent positions (20 points).

Companies that wish to apply for Corporate Account status must address all of the selection criteria in their application, which should not exceed two pages and must be signed by the corporate applicant or human resources director. Applications must be submitted via email to the corporate accounts unit indicated in the announcement. The Department of Home Affairs will make the final selection and will advise applicants on the outcome.

BAL Analysis: The one-stop-shop premium service should facilitate visa applications for select companies with high volume of work visa applications.

This alert has been provided by the BAL Global Practice group and our network provider located in South Africa. For additional information, please contact your BAL attorney.

Copyright © 2016 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.