Mbongeni TshabalalaPimville Zone 2Soweto, JohannesburgEmail: tshisaaka@gmail.comDate: 25 April 2025

To:The Head of SMME DevelopmentCity of Johannesburg – SMME Department[Department Address]

Subject: Request to Simplify Title Deed and Shop Layout Plan Requirements for Township SMMEs

Dear Sir/Madam,

I trust this letter finds you well.

As a graduate with an Honours in Public Management and Governance, I have been unemployed for over four years since graduation. My SEDFA TREP funding application is currently on hold because I am unable to obtain the required regulatory certificates due to prohibitive costs and administrative delays.

I am writing as an aspiring township entrepreneur and SMME applicant to highlight two specific administrative hurdles that disproportionately affect small businesses in townships like Pimville: I am writing as an aspiring township entrepreneur and SMME applicant to highlight two specific administrative hurdles that disproportionately affect small businesses in townships like Pimville:

Title Deed Verification Requirement• Current policy demands certified copies of property title deeds or formal consent from property owners for every business premise.• Many entrepreneurs operate from rented garages, informal structures, or family-owned properties without formal title deeds.• Procuring certified property documents or owners’ affidavits adds cost (±R200–R300) and time delays of weeks.

Shop Layout Plan (House Plan) Submission• Applicants must submit a professionally drafted house plan or architectural layout for approval before a business licence or acceptability certificate is issued.• Small-scale operators often lack access to qualified draughtspeople and cannot afford the R800–R1 000 professional fee.• This requirement stalls start-up activity and increases reliance on expensive consultants.

Impact on Township EntrepreneursThese two requirements alone can cost between R1 000 and R1 500 before any licensing fees. For many unemployed graduates and micro-entrepreneurs, these upfront costs — coupled with repeated visits to multiple municipal departments — render the business registration process prohibitively expensive and time-consuming.

RecommendationsTo empower black SMMEs and align with the City’s commitment to economic inclusion, I propose the following reforms:

Flexible Title Deed Compliance:• Allow a sworn affidavit from the landlord or property owner in lieu of a certified title deed.• Accept municipal rate account statements or utility bills (with business address) as proof of consent.

Simplified Shop Layout Submission:• Permit scaled hand-drawn sketches or standard DA‑approved template plans for businesses under 30 m².• Offer an online form where applicants can upload a basic layout diagram without requiring a professional draught.

One-Stop Township Service Point:• Establish a dedicated counter or online portal for township SMMEs, consolidating title deed consents, layout approvals, and health‑safety applications.• Provide clear checklists and SMS status notifications to reduce unnecessary visits.

Fee Waiver for First-Time Applicants:• Introduce a reduced or waived fee for title deed consent and layout plan reviews for qualifying black-owned township SMMEs.

Implementing these measures will significantly reduce the cost, complexity, and time required to obtain regulatory certificates, enabling entrepreneurs like myself to access SEDFA funding and create jobs in our communities more swiftly.

Thank you for your consideration. I would welcome the opportunity to discuss these proposals in more detail and assist in piloting a streamlined process for township-based businesses.

Yours faithfully,

Mbongeni TshabalalaFounder, Levi’s Fast FoodDA Activist