Fintech company Motswagae Holding, based in Pretoria, has filed an official complaint with the Competition Commission. The company accuses South Africa's largest banks of blocking access to ATM networks necessary for its cashless payment platform to function.
The company, which is not widely known to the public, stated in its submission to the commission (case number 2026Jul0016) that there are 'structural barriers to access' in the banking sector. The accused parties include FirstRand, Standard Bank, Capitec, Nedbank, and Investec.
A commission representative, Siyabulela Makunga, told TechCentral that the commission received the official complaint on July 8, but he declined to comment on the substance of the claim or the possible start of an investigation.
According to Motswagae CEO, Wally Sifo Faloane, the complaint is addressed not only to the five banks but also to the South African Reserve Bank (SARB) and the Intergovernmental Fintech Working Group (IFWG). At the heart of the dispute is the 360Wallet platform, which, according to Motswagae, will allow consumers to withdraw or deposit cash at any participating ATM using a voucher or e-wallet token, regardless of the issuing bank.
Currently, a person who receives money via a cashless voucher—a common way to connect with unbanked individuals—can usually only withdraw it from their issuing bank's ATMs or through its selected retail partners. Motswagae claims that its system will dismantle these isolated structures and reduce transaction costs for low-income and unbanked consumers.
The company insists that its platform is the subject of a patent application in South Africa. Furthermore, it refers to the IFWG regulatory sandbox—an initiative allowing fintech companies to test ideas under the supervision of the Reserve Bank and other financial regulators—which determined on June 30 that 360Wallet complies with existing payment rules and does not require regulatory exemptions to operate.
Faloane stated in the submission: 'Regulators have certified that our system is legally valid and does not require special legal exceptions to operate.' He added that this proves that obstacles to innovation in financial accessibility are structural, not regulatory. When established financial infrastructure refuses to interact with proven, cheaper services for small and medium businesses, the ordinary consumer pays the price in the form of inflated transaction fees.
However, the sandbox letter provided by Faloane to TechCentral reveals a more complex picture. The document dated June 30 states that Motswagae's application to test 360Wallet 'was rejected.' The letter explains that the sandbox only accepts innovations that clearly do not comply with current rules, and that 'there is no need for regulatory support that could be assessed,' because 360Wallet is 'conceptually closer to activities provided for by existing regulations,' referencing the 2007 directives mentioned in Motswagae's submission. Ultimately, the application was deemed unsuitable for further consideration.
Faloane interprets this outcome as confirmation of his correctness: if regulators see no need for regulatory support, he believes the barriers to 360Wallet are commercial, not legal. The Reserve Bank, acting as the secretariat for IFWG, partially supports this view, stating that the sandbox 'is not a market access mechanism,' and the rejection does not prohibit the product from entering the market; if an innovation does not require regulatory support, 'it generally indicates that it can operate within existing regulatory frameworks.'
Nevertheless, the letter does not certify 360Wallet as 'legally valid,' as Faloane claimed. Its phrasing is explicitly cautious—'seems,' 'does not seem'—and does not draw conclusions about the legality of the model. Moreover, the possibility of legal operation does not oblige any bank to connect to the platform, which is the commercial issue underlying the complaint.
In addition to confirming receipt of the complaint and correspondence with Faloane, the company's statements could not be independently verified as Motswagae's website was down at the time of publication. The complaint to the commission is an assertion by the filing party and does not mean the commission has found any violations or even intends to investigate the case.
Motswagae's submission also includes an accusation against the Reserve Bank of 'centralized control,' ignoring proposals sent to Governor Lesetj Kganyago, and responding through lawyers instead of direct engagement. The central bank categorically rejects this characterization, presenting a completely different version of the legal development of the dispute.
The Reserve Bank's media office responded to TechCentral's questions: 'SARB does not accept the characterization that it engages in 'centralized control' or that it has refused to engage on this matter.' It continued: 'Mr. Wally Sifo Faloane of Motswagae Holding (Pty) Ltd sent a demand letter containing false allegations against SARB, in which he threatened legal action. Therefore, SARB will not comment further pending a possible legal process.'
The central bank also objected to the link the company draws between the sandbox and the access complaint: the sandbox 'does not address issues of commercial access and therefore does not create any structural barriers, nor does it impede participation in the national payment system,' the organization stated.
TechCentral reviewed Faloane's demand letter of June 24, addressed to Kganyago. It contains an accusation of 'administrative negligence' against the IFWG secretariat due to delays with the sandbox and demands recognition of a separate proposal for payment modernization submitted to the governor's office on April 30. Otherwise, Motswagae warned that it would appeal to the High Court and refer SARB to the commission as a 'facilitator of market exclusion.' In fact, this is what happened. The sandbox rejection came on June 30, and the Reserve Bank's legal response on July 1 refutes all accusations and warns of intent to seek a 'punitive legal fine' if Faloane proceeds to court.
TechCentral also saw a strategic document from April 24, which Motswagae claims accompanied its proposal. In it, 360Wallet is described as 'production-ready' and positioned as a modern successor to Saswitch, a ten-year-old interbank ATM switch that was not originally designed for cashless withdrawals. The document also shows that Faloane viewed the sandbox as 'control that disproportionately protects the market position of incumbent banks' back in April, two months before the application was rejected, and decided to commercialize the platform through avenues 'independent of IFWG sandbox approval.'
Faloane also points to the timeline: in June, after his proposal, the Reserve Bank published its position paper 'To a Cash-Oriented Society,' which supports white-label ATMs—ATMs operated by entities other than large banks. He claims that his 'own strategic models were used to inform these regulatory and institutional directions behind closed doors.'
This document proposes a white-label ATM structure, but TechCentral found no evidence of any connection to Motswagae's proposal. Meanwhile, the company's own strategic document bases its argument on the Reserve Bank's policy documents published prior to this proposal, starting with the interoperability consultation in March 2025 and ending with the 'Vision 2030+' document from February 2026.
Motswagae's complaint falls within a broader industry debate about who gains access to South Africa's payment infrastructure. The Reserve Bank's payment modernization program envisions a national payment utility built on open, interoperable infrastructure, partly because cash remains sustainably dominant and costs the economy approximately 30 billion rand annually.
The industry's flagship interoperability project, PayShap, attracted millions of users but faced issues due to fees and uneven implementation by banks, after which it shifted its focus to merchant payments.
Faloane concludes the statement by saying that Motswagae remains 'deeply committed to collaborating with all progressive banking partners, retail networks, and regulators who share the national goal of modernizing our payment systems and ensuring genuine mass economic inclusion.'
