The South African Property Owners Association (SAPOA) refers to the Municipality’s correspondence regarding the request to extend the objection period applicable to the 2026 General Valuation Roll.

SAPOA confirms its support for the request that the closing date for objections be extended to 30 April 2026.

SAPOA is the representative body for the commercial and industrial property sector in South Africa and currently represents approximately 1,200 member companies and organisations. Our members include major financial institutions, listed property funds, property developers, asset managers and public entities such as ABSA, Nedbank, Investec Property Group, Old Mutual Properties, Liberty2Degrees, Eskom, Transnet, East London IDZ, Growthpoint Properties, the V&A Waterfront Company, ACSA, Eris Property Group, Encha Properties, Zenprop, Redefine Properties and Resilient REIT.

Collectively, SAPOA members own, manage or control approximately 90% of the commercial, retail, office, and industrial property stock in South Africa, with an estimated value of approximately R500 billion. As a result, SAPOA members constitute some of the largest municipal ratepayers in the country, including within the jurisdiction of the eThekwini Municipality.

The request for an extension of the objection period is therefore made in a broader representative capacity on behalf of the commercial property sector and SAPOA members, many of whom own or manage significant property portfolios within the eThekwini municipal area.

SAPOA acknowledges the Municipality’s efforts to comply with the statutory framework prescribed by the Local Government: Municipal Property Rates Act 6 of 2004 and the communication measures implemented to inform property owners of the valuation roll process. However, compliance with the minimum statutory requirements does not necessarily ensure that property

owners have had a reasonable and practical opportunity to properly review the roll and prepare meaningful objections.

The review of a valuation roll for large commercial property portfolios is a complex and resource-intensive process. It requires the verification of property attributes, analysis of market evidence, consultation with professional valuers, and internal review processes within asset management and governance structures. This process often involves multiple stakeholders and cannot reasonably be completed within a short timeframe, particularly where large portfolios of properties are involved.

While property owners are not required to wait for the receipt of their Section 49 notices before reviewing the roll, the practical reality is that these notices remain the primary trigger that alerts many owners and asset managers to the need to review specific property valuations. Where such notices are received later in the objection period, the effective time available for proper review is materially reduced.

SAPOA is therefore of the view that an objection period of approximately six weeks for a metropolitan municipality of the size and complexity of eThekwini is not sufficient to enable many property owners to properly exercise their statutory right to object.

Allowing a reasonable extension would not prejudice the valuation process. On the contrary, it would enhance the quality and completeness of objections, thereby assisting the municipal valuer and the valuation appeal structures in ensuring that the valuation roll is accurate and credible.

An extension to 30 April 2026 would provide property owners and institutional investors with a fair and reasonable opportunity to properly assess the values reflected in the roll and to submit well-motivated objections supported by relevant valuation evidence.

SAPOA therefore respectfully requests that the Municipality give favourable consideration to the request to extend the objection period in the interest of transparency, administrative fairness, and meaningful stakeholder participation in the valuation process.

We appreciate the Municipality’s willingness to consider this request through its governance processes and look forward to the Municipality’s response.