Vendor registration for contractors in South Africa did not change on 17 September, and that is the news. The Constitutional Court has struck down the Public Procurement Act, the law that would have folded every municipal supplier database into one national list. You register where you registered before the ruling: on the Central Supplier Database, which is mandatory, and on the supplier list of each municipality that still keeps one.
That answer will surprise anyone who half-heard that procurement law changed. It did, in the sense that a law was removed. Nothing was added, and the regime you register under is the one that existed before the Act was passed.
What the court decided
On Thursday 17 September 2026 a unanimous court declared the Public Procurement Act 28 of 2024 invalid in its entirety. The judgment, by Nuku AJ, decided the consolidated applications of the Premier of the Western Cape and the City of Cape Town (CCT 103/25 and CCT 144/25). The Speaker and the Finance Minister were ordered to pay the applicants' costs. GroundUp reported the ruling on 17 September.
The ground that carried was public participation. The Legal Resources Centre's note on the judgment records the court finding that Parliament failed its duty under sections 59(1)(a) and 72(1)(a) of the Constitution. Stakeholders had three and a half weeks for written submissions, four hours to consider amendments and two minutes each to present. The City had also argued that seven of nine provinces had no lawful final mandate when the National Council of Provinces voted.
Two things settle where that leaves you. The declaration of invalidity was not suspended; the court struck the Act down with immediate effect and did not send it back to Parliament with instructions.
And the Act had never been brought into operation. The court noted that existing legislation had continued to regulate public procurement throughout, so there is no gap to fill. The court removed a future regime rather than a live one. Until a new act passes, the Public Finance Management Act, the Municipal Finance Management Act, the Preferential Procurement Policy Framework Act and the 2022 Preferential Procurement Regulations go on applying exactly as they did.
What the Act would have done to your registrations
The Mayor's statement, carried by Infrastructure News, lists what the City objected to. It is the only account of the Act's contents in our archive, and this piece does not go beyond it.
- Municipalities would no longer maintain their own database of accredited suppliers and payment records. They would integrate with a national database instead.
- All procurement would be centralised through a Public Procurement Office, with the risk of nationwide disruption if the central system went offline.
- A municipality's power to deviate from procurement regulations for urgent service delivery would go, unless the Public Procurement Office approved.
- Around 36 elements of the Act would have needed new regulations before they could operate.
Read that list from a contractor's side. Every local supplier list you have ever registered on would have been replaced by one national record. That is not obviously worse for a contractor. One registration instead of eleven is a saving, and the City's objection was about municipal autonomy, not about your admin. It is simply not what is going to happen now.
The Mayor's own figure for what was at stake in Cape Town is R12,2 billion of infrastructure investment in the last year, 75% of it directly benefiting lower-income households. All of it was procured under municipal rules, and will go on being.
Where do contractors register now?
Contractors register on two lists, and a third is easy to miss.
The Central Supplier Database first. SME South Africa's guide, updated on 3 September, states that CSD registration is mandatory regardless of where in the country you trade, and that the self-registration process is lengthy. It is the list every organ of state searches, and it is the first of the five registers we check on any contractor. Nothing in the ruling touches it.
The municipality's own database second. The same guide says the CSD framework has largely replaced these, so most municipalities no longer keep one. The ones that do are where the small work is instructed from, and none of that work reaches eTenders.
Our check of municipal noticeboards on 18 September found fifteen construction-relevant notices from Madibeng and Metsimaholo alone. Read that with care. When those two pages were opened by hand on 12 September, most of the items were archived adverts from earlier years, so it is not fifteen live jobs. What it proves is that both municipalities keep their own list and post to it, which is exactly the arrangement the Act would have ended.
The third is the departmental pre-approved list. On 18 September at 11:00 the Gauteng Department of Human Settlements closed applications for a pre-approved list of service providers for the protection, monitoring and prevention of unlawful occupation, under reference HLA 4/2/4-2026/02, on eTenders. That one is a protection list, not a construction one, but the mechanism is the point. A department builds its own list, appoints from it for a term, and a firm not on it is not asked. Neither the CSD nor a municipal database gets you onto one, which is why joining a contractor panel is its own job.
What to do on Monday
Log into your CSD record and check three fields: the directors listed, the commodity codes, and the tax status showing. Then write down the four municipalities you actually want work from and open each one's supply chain page. If it runs its own supplier database, register on it this week. If it says CSD only, note the date you checked, because that answer can change.
Do not wait for Treasury's next move. The Finance Minister told Business Day that government will go back to the drawing board for a new procurement act. No new bill has been tabled, and until one passes the CSD is untouched and the municipal lists still exist.
There is one more list, and it is private. A contractor verified once and visible to every client commissioning work is what the Act promised the public sector, and the court has now removed it there. Arabella Infrastructure Solutions is a Johannesburg-based building maintenance and construction company that does that verification for private clients, once, on documents rather than declarations. The contractor stays visible for as long as the documents hold. What it involves is on the contractor page.
