South Africa's National Student Financial Aid Scheme (NSFAS) is facing renewed scrutiny regarding payments made to advisers working for its administrator, Hlengani Mathebula. The payments have drawn criticism amid an ongoing procurement dispute, bringing the financial aid body's operational practices into question. This fresh scrutiny stems directly from the payments made to administrator Hlengani Mathebula’s advisers, which have raised significant concerns about compliance with public finance regulations.
Questionable Adviser Payments
Two advisers to Hlengani Mathebula, Nonkululeko Manyika and Dudu Hlatshwayo, utilized their private companies, Nonisa and ChangeEQ, to submit monthly corporate tax invoices for services rendered. These invoices amounted to nearly R500,000 for 30 days, reportedly without an open supply chain management (SCM) tender process. The direct invoicing through private entities has ignited questions about the transparency and legality of these arrangements. On July 31, 2026, a single FNB batch payout totaling R459,140.18 was transferred to these private adviser companies, ChangeEQ and Nonisa, marking a significant financial transaction that bypassed standard procurement protocols.
Mathebula's four-member advisory team operates with an official price tag of R9.9-million per year, resulting in an average cost of R2.47-million per adviser annually. This substantial budget allocation for advisory services has come under the spotlight. Dudu Hlatshwayo’s private firm, ChangeEQ, billed NSFAS R254,973.51 for July 2026. This sum included R32,500 in Value Added Tax (VAT) and R5,806 for accommodation expenses, detailing the various components of the monthly charge. At this monthly invoicing rate of R254,973.51, Hlatshwayo is projected to collect more than R6.1-million over a 24-month tenure through ChangeEQ. Simultaneously, Nonkululeko Manyika’s corporate entity, Nonisa, invoiced R204,166.67 for July 2026 for providing consulting and financial advisory services, contributing to the nearly R500,000 monthly total for the two firms.
NSFAS Procurement Stance
The National Student Financial Aid Scheme (NSFAS) has asserted that procurement requirements under the Public Finance Management Act (PFMA) do not apply to its adviser contracts. NSFAS claims these advisers were appointed in accordance with a ministerial Government Gazette, which it argues provides a distinct basis for their engagement. However, Section 5.6.3 of the NSFAS Supply Chain Management (SCM) policy mandates that any commercial contract for goods or services exceeding R1-million must be openly advertised on the National Treasury e-Tender portal for a minimum of 21 calendar days. This policy provision appears to directly contradict the method used for the adviser appointments, as neither the ChangeEQ nor the Nonisa contract was subjected to a public tender process, despite their projected contract values each reaching R6-million.
National Treasury commented on the matter, stating, "The PFMA does not provide for a separate, standalone framework for the appointment of advisers." National Treasury further clarified that public entities and departments are "required to ensure that any such appointments comply with the PFMA principles, Treasury regulations, applicable Instruction Notes, and the entity’s approved policies." This statement indicates a need for adherence to established financial governance frameworks, irrespective of the appointment mechanism cited by NSFAS. The Treasury's position emphasizes that all public sector appointments, including those for advisers, must conform to the overarching principles of financial transparency and accountability.
Treasury Rejects NSFAS Claims
National Treasury spokesperson Tabby Tsengiwe stated that the Treasury holds no record of granting any exemption to the National Student Financial Aid Scheme (NSFAS) from applicable Public Finance Management Act (PFMA) and Supply Chain Management (SCM) prescripts concerning the adviser appointments. Tsengiwe emphasized, "National Treasury is not aware of any exemption granted to NSFAS from applicable PFMA and SCM prescripts in relation to these appointments. NSFAS would be best placed to account for the legal basis for the appointments and the processes followed." This statement directly challenges NSFAS's claim of exemption based on a ministerial Government Gazette, placing the onus on NSFAS to justify its procurement methods.
The Treasury reiterated that the PFMA does not establish a distinct framework for adviser appointments. According to the National Treasury, "The PFMA does not provide for a separate, standalone framework for the appointment of advisers. Public entities and departments are, however, required to ensure that any such appointments comply with the PFMA principles, Treasury regulations, applicable Instruction Notes, and the entity’s approved policies." This statement shows the expectation for all public entities to adhere to existing financial governance frameworks. A request for concurrence regarding the appointments, submitted to Finance Minister Enoch Godongwana, remains "currently under consideration" by the Treasury, indicating that a final decision on the legality of these compensation arrangements is still pending.
Official Clarifications
Neither the contract for ChangeEQ nor Nonisa was subjected to a public tender process, despite their projected contract values each reaching R6-million. This lack of an open tender process is a key point of contention, particularly given the large sums involved and the clear directive in NSFAS's own SCM policy. The National Treasury further confirmed that Finance Minister Enoch Godongwana has not granted statutory written concurrence for the compensation of the administrator or his advisers under Section 17 C of the NSFAS Act. This lack of formal ministerial approval adds another layer of concern regarding the legitimacy of the payments. The Treasury clarified that the Public Finance Management Act (PFMA) does not establish a distinct framework for the appointment of advisers. "The PFMA does not provide for a separate, standalone framework for the appointment of advisers," National Treasury stated. The Treasury added that public entities and departments "are, however, required to ensure that any such appointments comply with the PFMA principles, Treasury regulations, applicable Instruction Notes, and the entity’s approved policies." This stance emphasizes the mandatory adherence to existing financial governance frameworks for all such appointments, reinforcing the principle that no public entity is exempt from these regulations without explicit and documented approval. The ongoing consideration of the request for concurrence by Finance Minister Enoch Godongwana notes the gravity of the matter and the need for a definitive resolution on the compliance of these adviser contracts.
