DHET Registration for all Skills Providers: Compliance or Business Sense 5

In February 2017, I published an article on LinkedIn

The crux of the matter was merely that although most of the DHET registration requirements may make perfect business sense, the use of outdated application and in some instance, irrelevant Legislative DHET requirements for particularly Skills Providers may cause detrimental unintended consequences. (One size does not fit all!!!!)

I am sad to say that I am sad that that my worst fears were not in vain, perhaps to the total collapse of Private Skills Providers or at least to some “suitcase providers”. This term is not derogatory or any indication that such providers provide a critical service to clients. They simply provide a service on the client’s premises or utilise compliant venues at great costs.

In fact, these providers sometimes have to provide their service at “non-compliant venues” situated mostly in public institutions. I am providing a brief outline of conditions and concerns encountered in my personal capacity

  • The evaluator or auditor will scrutinise evidence against the current requirements stipulated on the application document at hand, simply stated if the document requires that “PTY LTD” is required, the evidence must support it.
  • Leading from the aforementioned, the current application document is to register as an “FET College”. Skills Providers are NOT applying to register as Colleges.
  • With due regards to the unique challenges facing Public Institutions of learning, I quote the following statement from the Section 29 of the Bill of Rights (Education) “maintain standards that are not inferior to standards at comparable public educational institutions”. does it infer that we have “inferior” public institutions and if so is there a list available?
  • From personal experience, regarding occupational health, safety and hygiene, I am familiar with the excellent facilities maintained by some public institutions, I am also familiar with some life-threatening facilities evident in others.
  • Similarly, the same can be said about private institutions.

In summary, my view as mentioned in the LinkedIn article on the current DHET Registration process of Skills Providers is not a well-structured process. It’s also my duty as an HRD professional and fellow custodian of occupational health, safety and hygiene to raise concern and awareness of non-compliance with prevailing conditions wherever they exist.


Published on February 3, 2017

Alfie R Wagner CHRP

HRD Practitioner Learning and Development Strategist Quality Assurer Independent SDF *OHS Auditor

DHET Registration for all Skills Providers: Compliance or Business Sense

DHET Registration for all types of Private Skills Development Providers now seems to be a reality. While many other subject experts unpack the magnitude of challenges facing Skills Development Providers, I am thinking “what the heck is DHET registration”?

SETA Accredited Providers, who’s ultimate quality accountability resides with the QCTO may or may not find DHET Registration somewhat challenging. I am hoping this article, in layman’s language as much as possible, will assist Skills Development Providers to prepare for registration.

Legislative Registration Requirements (Government Gazettes and related notices) and business sense.

  1. Administrative Data: The business name, address and contact details.
  2. Business Registration Particulars: PTY Ltd as defined is a requirement and audited financial statements required.
  3. Holding Company Details: franchise, licensing details where applicable.
  4. Management Particulars: details of persons responsible for different parts of the company.
  5. Qualification Details: products and service offered (All Skills Providers must include QCTO, SETA qualifications and Skills Programmes in registration application. (if SETA ETQA accredited, the programmes would have been evaluated and approved in any case, likewise with QCTO qualifications).
  6. Staff & Student Data: Who works where and what are their functions (teach, support functions), and the clients (students) information.
  7. Financials & Legal Documents: Business Plan (forecasts, market, risks, SWOT, financial security / surety).

Tax affairs and Occupational Health, Safety & Environment OHSE in          order (This is a requirement for all business entities operating in South Africa).

(DHET OHS Compliance Audit requirements stipulate that the auditor issuing the report must be registered with the South African Institute of Occupational Safety and Health (Saiosh) as Graduate Member (GradSaiosh) and proof of registration must be attached to the Occupational Health and Safety report.

Although the current Saiosh Auditor registration notice, applies to Higher Education applications it may well be a requirement for submission of QCTO requirements.

  1. Quality Assurance: This would state the intentions, processes and procedures (QMS and related Standard Operating Procedures) on how the company conduct their business processes (Already in place and quality assured internally and externally) as an accredited Skill Development Provider.
  2. Information for Students and the Public: What products and services does the Skill Development Provider offer (where, when, how).

In my view all nine points above make business sense in the following manner;

Registering a business as defined is legislated and compliance to relevant legislation such as basic conditions of employment, labour relation, occupational health safety and environment and other relevant compliance (depending on industry sectors) are defined

  • One would have a business plan and if it is currently not documented, that should not be too difficult to document it
  • The company structure, policies, processes and procedures should be a given if a company want conduct business in an orderly fashion
  • The above would include marketing and statistical data

In the areas where challenges arise, one could find a good old fashion “Credible Tailor to tailor your suit”. These days it is called “outsourcing”. A very important point to remember is that you “the company” have to wear it (the suit that is).

The biggest challenge I believe is the following Government Gazettes, that also found their way onto the QCTO website as “new” on 2 January 2017.

Gazette No. 30732, dated 5 February 2008 (Registration of Private Further Education and Training Colleges)

Gazette No. 30733, dated 5 February 2008 (Application for amendment of registration as a Private Further Education and Training College)

Gazette No. 30735, dated 5 February 2008 (Application for registration as a Private Further Education and Training College)

The following, relating to the current application documents is worrying to say the least;

 Nowhere on the guideline document and application form does is it indicate any other qualifications other than NQF Level 2 to 4 qualifications.

The name DHET don’t even appear on the documents.

In my view this document in its current form is not suitable or “fit for purpose” to apply for DHET Registration as is. Having said that, the requirements for DHET registration makes total sense.

Alfie R Wagner CHRP

Saiosh Graduate Member

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5 thoughts on “DHET Registration for all Skills Providers: Compliance or Business Sense

  • Molebatsi Lewele

    thanks so much for your detailed feedback, you know I was even thinking this is impossible, but with your response you gave me hope to get back and do my application.

  • Nigel Shipston

    Hi Molebatse,
    It would appear that the safest way of getting the application submitted is to do so at the Head Office. Some of the requirements are not much of an issue, the only one about which there is currently major contention is that of financial reporting. Most providers fall in the SMME category which, according to the Companies Act 2008 requirements, means that you need only an Accounting Officers Report. DHET are however, in conflict with the Companies Act requirements, expecting all providers to submit audit reports by IRBA auditors.

    Unfortunately, DHET have been briefly reviewing applications at their front entrance, and turning applications away for any infringements. This is highly irregular, as no matter what the status of an application, you as a training provider are required to apply for Registration. DHET must accept your application, firstly as proof that you have in fact applied as per the Communique. According to the regulations pertaining to Registration applications, the Registrar is required to acknowledge receipt of the application, therefore they are not permitted to turn any applications away at the front office. It is imperative that all providers submitting applications insist that the Application be received, recorded and ultimately acknowledged.

    Without this acknowledgement, irrespective of any shortcomings in the application, providers have no proof of complying with the compulsory Registration application requirements. Having acknowledged receipt of your application, a DHET Evaluator will go through your application and send you a report as to what the shortcomings are. Normally they give around a 2 month period in which to rectify the problems.

    The most important thing to remember is to submit your application in order to show that you have complied with the first part of the Communique, namely that all Private Training Providers must register with DHET.

  • Nigel Shipston

    Hi Alfie,
    Indeed it is not a well structured process, but if you refer to the “WHITE PAPER FOR POST-SCHOOL EDUCATION AND TRAINING, BUILDING AN EXPANDED, EFFECTIVE AND INTEGRATED POST-SCHOOL SYSTEM” (As approved by Cabinet on 20 November 2013), in the section relating to private training providers, you will note that there were a number of actions that should have been carried out before this Registration process started. Three and a half years after this White Paper, nothing has been done in approaching the process, so the Registrations were initiated against outdated legislation and evaluators seem oblivious of the new Companies Act requirements.

    We have tested the system, and despite various communications with the relative authorities for the last 4 months, there has been no relief from this ridiculous situation and we are no closer to a resolution yet. What is distressing is that the signatories to the Joint Communique have given no feedback, nor is there any indication of the situation changing. When the deputy President publicly announces that education and training is about job creation, one has to wonder how they intend doing that when literally thousands of Private Training Providers are being threatened with closure. Not only are they going to reduce the training effort with thousands of providers disappearing, but they are going to expand the unemployment market.

    I agree that the intention behind registration is a reasonable business decision, had there been sufficient preparation on the part of the authorities, to research the industry and provide a process that recognises the context in which we work. There are numerous references to comparisons with “public colleges”, and this is the crux of the problem. There can be no comparison between a private training provider and a public college. The two operate in totally different environments and operational functions and hiding behind public colleges as the shining example is misguided, misinformed and quite frankly, lacking any form of reasonable logic.