TOOLS / REGULATION 28 CALCULATOR

Does this fund fit inside the limits?

Type a South African retirement fund's asset allocation and see every Regulation 28 asset-class limit measured against it, plus the 45 percent offshore limit that exchange control sets separately. Every figure is read from the gazette that set it.

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What the fund holds

Each figure is a percentage of the fund, which is the base every limit is measured against. Leave a line blank if the fund holds none of it. Nothing you type leaves your browser.

South African assets

%

JSE listed shares. Property companies count as property.

%

Issued or guaranteed by the Republic. May fill the whole fund.

%

Bank, corporate and other debt the Republic does not stand behind.

%

Deposits, money market and margin balances.

%

REITs and listed property collective investment schemes.

%

Krugerrands and locally listed exchange traded commodities.

%

The invested amount, in a fund regulated here.

%

Its own limit since 2023, no longer shared with hedge funds.

Foreign assets

Every line here adds to the 45% offshore limit.
%

Counts against the equity limit as well.

%

Shares the 75% line with South African corporate bonds.

%

Deposits and money market with a foreign bank.

%

Counts against the 25% property limit as well.

%

Offshore gold and commodity vehicles.

%

Counts against the 10% hedge fund limit as well.

%

Counts against the 15% private equity limit as well.

Everything else

%

A retirement fund may hold none of it.

%

Anything items 1 to 9 of Table 1 do not cover, wherever it sits.

These lines add to100%

Within every limit this page checks

The offshore share is 30% against a limit of 45%, leaving 15% of the fund that could still go abroad. Every other measured limit has headroom too. This covers the asset-class limits and the offshore limit only, not the per-issuer limits or infrastructure.

Every limit, and where this fund sits against it

Headroom is what the fund could still add to that line before it hits the limit.

LimitHeldMaximumHeadroomStatus
Offshore, all foreign assets together
EXCHANGE CONTROL
30%45%15%Within
Equities
REGULATION 28
70%75%5%Within
Immovable property
REGULATION 28
5%25%20%Within
Commodities
REGULATION 28
0%10%10%Within
Hedge funds
REGULATION 28
0%10%10%Within
Private equity
REGULATION 28
0%15%15%Within
Other assets not named in Table 1
REGULATION 28
0%2.5%2.5%Within
Crypto assets
REGULATION 28
0%NoneNoneWithin
Debt other than the Republic's
REGULATION 28
10%75%65%Within
Debt issued or guaranteed by the Republic
REGULATION 28
10%100%90%Within
Cash
REGULATION 28
5%100%95%Within

The asset-class limits come from Table 1 of Regulation 28 as substituted by Government Gazette 46649, Notice 2230, published 1 July 2022 and effective 3 January 2023. The offshore limit is exchange control rather than Regulation 28: SARB Exchange Control Circular 10/2022, unchanged as at Circular 2/2025.

What this checks, and what it does not

Checked

  • Every asset-class limit in Table 1, measured on the totals you enter
  • The offshore limit, summed from every line you enter as foreign
  • Both halves of the debt limit, by who issued the debt
  • The crypto prohibition, which no amount satisfies
  • Whether the lines add to the whole fund

Not checked

  • Infrastructure, across every asset class, 45%
  • Any one issuer, across every asset class, 25%
  • Debt, by the kind of issuer, inside the 75%, 75%, 50% or 25%
  • One listed company, by its market capitalisation, 15%, 10% or 5%
  • One listed property company, by its market capitalisation, 15%, 10% or 5%
  • Housing loans to members, 65%
  • The business of a participating employer, 5%, or 10% by exemption

Everything on the right needs the fund’s actual holdings rather than its asset-class totals, and several need a look-through into pooled vehicles. One line carries no domicile: item 10’s residual is capped at 2.5% of the fund wherever it sits, so at most that much can be held abroad without appearing in the offshore total. A pass here is a check on the numbers you typed, not a compliance certificate: trustees and administrators remain responsible for the fund’s reporting. Figures within 0.1% of the whole fund are treated as rounding.

Build one that fits from the start

Checking an allocation afterwards tells you whether it breaks a limit. The optimizer takes the limits as constraints first, so every mix it proposes already sits inside them, and prices the result on published return forecasts rather than a guess.

Open the workstationOpen the portfolio optimizer

What Regulation 28 is

Regulation 28 is made under section 36 of the Pension Funds Act and says how much of a South African retirement fund may sit in each kind of asset. It applies to pension funds, provident funds, preservation funds and retirement annuities, which is why a fund fact sheet marked Regulation 28 compliant carries the same ceilings whichever manager runs it. The limits are ceilings on the aggregate fair value of the fund’s total assets, so every figure on this page is a share of the whole fund.

The current asset-class table is Table 1, substituted in full by Government Gazette 46649, Notice 2230, published 1 July 2022, effective 3 January 2023. That amendment lifted private equity to 15 percent and gave it an item of its own, raised the infrastructure aggregate to 45 percent, and prohibited crypto-assets outright. A spreadsheet built before 2023 will still be running the old figures.

The limits, and who sets each one

The asset-class limits below are Regulation 28’s. The offshore limit is not in Regulation 28 at all, and it is listed separately for that reason.

Asset classLimitSource
Equities75%Regulation 28, Table 1, item 3
Immovable property25%Regulation 28, Table 1, item 4
Commodities10%Regulation 28, Table 1, item 5
Hedge funds10%Regulation 28, Table 1, item 8
Private equity15%Regulation 28, Table 1, item 9
Other assets not named in Table 12.5%Regulation 28, Table 1, item 10
Crypto assetsNoneRegulation 28, subregulation (3)(k)
Debt other than the Republic's75%Regulation 28, Table 1, item 2
Debt issued or guaranteed by the Republic100%Regulation 28, Table 1, item 2.1(a)
Cash100%Regulation 28, Table 1, item 1
Offshore, all foreign assets together45%Exchange control: SARB Exchange Control Circular 10/2022, dated 23 February 2022, unchanged as at Circular 2/2025

Several limits sit underneath these and need the fund’s actual holdings rather than its asset-class totals, so this page does not measure them.

  • Infrastructure, across every asset class, 45% (Table 1, item 11(a), and subregulation (3)(iA)). Infrastructure cuts across equities, debt and property rather than sitting in one of them, and only a holding list says how much of each is infrastructure.
  • Any one issuer, across every asset class, 25% (Subregulation (3)(h)). Measured per issuer, excluding debt issued or guaranteed by the Republic. It needs the names in the portfolio, not the totals.
  • Debt, by the kind of issuer, inside the 75%, 75%, 50% or 25% (Table 1, items 2.1(c), 2.1(d) and 2.1(e)). Under the 75% line, item 2 caps South African bank debt at 75%, listed corporate and public entity debt at 50%, and other debt at 25%. One corporate bond figure does not say which of those the fund holds.
  • One listed company, by its market capitalisation, 15%, 10% or 5% (Table 1, item 3.1(a)). R20 billion and above allows 15%, R2 billion to R20 billion allows 10%, and below R2 billion allows 5%. Unlisted shares are capped at 2.5% per company and 10% in total.
  • One listed property company, by its market capitalisation, 15%, 10% or 5% (Table 1, item 4.1(a)). R10 billion and above allows 15%, R5 billion to R10 billion allows 10%, and below R5 billion allows 5%. Unlisted property is capped at 5% per holding and 15% in total.
  • Housing loans to members, 65% (Table 1, item 7). Loans granted under section 19(5) of the Pension Funds Act. The 65% applies to guarantees entered into on or after 3 January 2023.
  • The business of a participating employer, 5%, or 10% by exemption (Table 1, item 6). Investment back into the employer under section 19(4) of the Pension Funds Act, which a member's allocation percentages do not show.

The per-issuer limits step down with the size of the company, so a small listed company allows a smaller position than a large one. Across every asset class the fund may not put more than 25 percent into any one issuer, counting everything except debt the Republic issues or guarantees.

Who sets the offshore limit

The 45 percent cap on foreign assets is exchange control. National Treasury sets it and the South African Reserve Bank’s Financial Surveillance Department administers it. SARB Exchange Control Circular 10/2022, dated 23 February 2022, put it in one sentence: the prudential limits of 30 percent and 40 percent and the African allowance of 10 percent were combined into a single limit of 45 percent of total retail assets under management, applicable to all qualifying institutional investors. Circular 2/2025 records the limit unchanged and notes the IMF recommended it not be reduced.

With offshore capped at 45 percent, at least 55 percent of a retirement fund is South African. That domestic floor shapes a fund’s answer more than any single Regulation 28 ceiling does, because it binds long before the 75 percent equity limit or the 25 percent property limit come into play.

Three things people get wrong

The 10 percent Africa allowance. It was absorbed into the 45 percent in February 2022. Circular 10/2022 kept African exposure as a reporting line on the quarterly asset allocation return for statistical purposes, and readers of that return keep inferring a sub-limit that no longer exists. A fund cannot add 10 percent of African exposure on top of 45 percent offshore.

The two 45 percents. Regulation 28 has a 45 percent of its own at item 11(a) of Table 1, and that one caps aggregate infrastructure exposure across every asset class, excluding debt issued or guaranteed by the Republic. The offshore 45 percent comes from exchange control. The numbers match and the rules measure entirely different things.

The FSCA’s limit. The Financial Sector Conduct Authority sets neither figure. Regulation 28 is made by the Minister of Finance under the Pension Funds Act, and the offshore limit is exchange control. The FSCA supervises retirement funds and receives their reporting, which is how it enforces limits it did not write.

Questions this page answers

What is the Regulation 28 offshore limit?

Regulation 28 does not set an offshore limit. The 45 percent cap on foreign assets is exchange control, set by National Treasury and administered by the South African Reserve Bank. SARB Exchange Control Circular 10/2022, dated 23 February 2022, combined the old 30 percent and 40 percent prudential limits and the 10 percent African allowance into a single 45 percent of total retail assets under management. Circular 2/2025 records it unchanged, noting that the IMF recommended the institutional limit not be reduced.

Does a fund still get an extra 10 percent for Africa?

No. The 10 percent African allowance was absorbed into the single 45 percent limit in February 2022 and no longer exists as an allowance. Circular 10/2022 kept African exposure as a line on the quarterly asset allocation report for statistical purposes, which is why commentary written after 2022 still quotes 10 percent. African exposure is a reporting category now, and a fund gets no extra headroom for holding it.

Is the 45 percent limit the same as Regulation 28's 45 percent?

They are two different limits that happen to share a number. Regulation 28 has its own 45 percent at item 11(a) of Table 1, and that one caps the fund's aggregate exposure to infrastructure across every asset class, excluding debt issued or guaranteed by the Republic. The offshore 45 percent comes from exchange control. A fund can be at 45 percent offshore and hold no infrastructure at all, or the reverse.

Does the FSCA set the Regulation 28 limits?

No. Regulation 28 is made by the Minister of Finance under section 36 of the Pension Funds Act, and the offshore limit is exchange control administered by the Reserve Bank. The Financial Sector Conduct Authority supervises retirement funds and receives their asset allocation reporting, so it enforces both figures and sets neither. Writing about the FSCA's 45 percent limit attributes the rule to the wrong body.

Can a South African retirement fund hold Bitcoin or other crypto?

No. The 2022 amendment inserted subregulation (3)(k), which reads that a fund may not invest in crypto-assets, including in relation to Item 10 of Table 1. That closes the residual other assets line as a route in. The prohibition is absolute. No allocation is small enough to comply.

Does listed property count toward the 75 percent equity limit?

No. Item 3.1(a) of Table 1 covers preference and ordinary shares while expressly excluding shares in property companies, and item 4 gives immovable property its own 25 percent limit. Listed property counts there instead, together with property linked units and listed property collective investment schemes, and South African and foreign property count against the same 25 percent.

Where do these limits come from?

Table 1 of Regulation 28 was substituted in full by Government Gazette 46649, Notice 2230, published 1 July 2022, effective 3 January 2023. That amendment lifted private equity to 15 percent and gave it its own item, raised the infrastructure aggregate to 45 percent, and prohibited crypto-assets. Every asset-class figure on this page is read from that table, and each row names the item it came from.

Is a spreadsheet enough to check Regulation 28?

The arithmetic is simple enough for a spreadsheet, and the mistakes are usually not arithmetic. Sheets built before 2023 still carry private equity at 10 percent, still show a separate African allowance, and often label the 45 percent as a Regulation 28 limit when it is exchange control. This page uses the current gazette figures and names the source next to each one so a sheet can be checked against it.

Does this calculator prove a fund complies?

No. It measures the asset-class limits and the offshore limit against the totals you type. It does not check the per-issuer limits, the infrastructure aggregate, housing loans, investment in a participating employer, or look-through into pooled vehicles, all of which need the fund's actual holdings. Trustees and administrators remain responsible for the fund's reporting.

Keep reading

Build a mix that fits the limits →
TOOL · CONSTRAINTS HELD BY THE SOLVER
What each asset class is forecast to return →
TOOL · FORECASTING HOUSES COMPARED
Where the return forecasts come from →
RESEARCH · THE HOUSES, SIDE BY SIDE
Running your own portfolio →
GUIDE · WHAT THE WORKSTATION DOES

A compliance check tells you whether a mix breaks a limit. The workstation holds the limits as constraints while it builds the mix, so what it proposes already fits.

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