Disputed debit orders: the 60-day rule and the mandate trail a brokerage needs

Contents

1. What changed on 13 April 2026
2. Know whose mandate you are standing behind
3. Five reasons an insurance collection fails, and what each one needs
4. Use the 60 days as a service window
5. What your records must show when a dispute lands
6. Frequently asked questions

Every brokerage that collects or chases premiums in South Africa has the same bad week each month. The collection file goes out, a handful of debits bounce for want of funds, and a smaller handful come back as something worse: a dispute. The client has told their bank they never authorised it. Cover falls away, commission is clawed back, and the conversation that follows is about trust rather than money. Since 13 April 2026 the rules around that dispute have been standardised across the industry, and the practical consequence for a brokerage is not less risk — it is a shorter, sharper window in which the whole thing is decided.

What changed on 13 April 2026

The payments industry — the Payments Association of South Africa, working with the South African Reserve Bank and the Financial Sector Conduct Authority — replaced a patchwork of dispute timelines with a single rule: the client has 60 calendar days, counted from the day after the collection, to dispute a debit order at their bank. The window applies across the low-value debit instruments a brokerage will meet in practice: ordinary EFT debits, DebiCheck and registered mandates. Once it closes, banks no longer process the dispute, and the client has to take the matter up with the biller directly.

Before the change, an EFT debit could be reversed almost automatically inside 40 days, and older collections could still be challenged through a slower manual route stretching close to a year. Two things follow for a brokerage.

• Exposure is concentrated, not reduced. Reversals now cluster in the two months after collection. A book with a January inception surge has a February and March reversal season, and it is over by April.
• The complaint lands on your desk instead of the bank's. On day 61 the client cannot get their money back from a banking app; they phone the person who sold them the policy. That call is not a payments query, it is a service moment, and it is usually the last one before a cancellation instruction.

There is a second-order effect worth naming. An authenticated DebiCheck mandate sits at the client's own bank, so a dispute against it generally has to allege that the amount or the date does not match what was authenticated. An unauthenticated EFT debit has no such anchor. Where your insurers give you the choice, the authenticated route is the one that survives a dispute.

Know whose mandate you are standing behind

Brokers get into trouble here by answering a question that is not theirs to answer. Before you promise a client anything about a collection, establish which of three positions you are in.

1. The insurer collects. You have no mandate, no collection file and no ability to stop, reverse or re-run anything. Your job is to explain, to escalate and to log the instruction — not to commit to a date.
2. You collect under a section 45 authority. Section 45 of the Short-term Insurance Act lets a short-term insurer authorise an independent intermediary to receive premiums, subject to security — in practice a guarantee — and to monthly returns to the insurer covering premiums received, commission and amounts paid over, delivered within 15 days after the end of the month. If this is you, the mandate trail is yours to defend, and so is the reconciliation.
3. A UMA or binder holder collects. You sit in the middle: you can see the outcome, you cannot change the file, and the client cannot tell the difference. Agree in advance who answers a dispute and how fast the outcome reaches you.

Write the answer down per insurer and put it where the servicing team can see it. Half the bad promises made on WhatsApp at month-end come from a consultant assuming position two while sitting in position one.

Five reasons an insurance collection fails, and what each one needs

An unpaid report lumps very different problems into one column. They are not the same problem and they do not deserve the same message.

Reason	What the client sees	What actually fixes it
Insufficient funds	Nothing, until the lapse notice	A collection date matched to the pay date, agreed once rather than chased monthly
Premium exceeds the authenticated mandate	A rejected debit after an annual increase	A new mandate authenticated at the higher amount before the escalation runs
Account closed or bank switched	Nothing — they assume the policy follows them	New banking details and a fresh mandate, then a confirmation in writing
Dispute lodged at the bank	The money back, and a policy they think is cancelled	The mandate evidence, and a conversation about what they actually wanted to stop
Timing against a public holiday or weekend	A debit on an unexpected day	A calendar check before the file goes out, not after

The second row is the one brokerages consistently miss. A DebiCheck mandate records what the client authenticated, including the maximum amount and any agreed adjustment. If the escalated premium goes beyond that, the collection does not fail because the client had no money — it fails because nobody asked them to re-authenticate. Annual increase season and rejected-collection season are the same season, and the fix belongs to the month before, not the month after.

Use the 60 days as a service window

Treat the dispute window as a service cadence rather than a legal deadline and it stops being frightening. A workable rhythm for a Southern African book, run from the shared inbox rather than a spreadsheet:

• Before the run: for clients whose premium changes this cycle, a plain message explaining the new amount and the date it will be taken. This single message prevents more disputes than any recovery script, because most disputes are surprise, not fraud.
• Within 48 hours of a rejection: a short utility-category template naming the policy, the amount and one clear option. Our failed debit order use case sets out the sequence, and the failed debit order notice template gives you wording that reads as service rather than collections.
• Day 7 to 10: if there is still no reply, a call. The timing of reminders around paydays and month-end matters more than the number of them.
• On a dispute: reach out the same day, in writing, and ask the question the bank never asks — what did you want to stop? A dispute is often an attempt to cancel a policy the client no longer values, and that is a retention conversation, not a payments one. Our note on lapse risk covers what to do with the answer.

In ORIS this is a segment and a Quick Campaign rather than an afternoon of copy-paste: filter the client list on the flag your unpaid reconciliation sets, send an approved utility template, and let the replies come back into the shared inbox where the whole team can see them. Clients who reply with an intention to cancel surface as attrition-risk opportunities instead of disappearing into one consultant's phone. Reconciliation against the insurer's own unpaid report is still a CSV export on both sides — ORIS does not plug into insurer systems, and any broker who tells you their CRM does should be asked to show it.

What your records must show when a dispute lands

Whether you defend the mandate or simply explain it, the evidence is the same set of artefacts, and the 60-day clock means you may need them quickly.

• The mandate itself: how it was obtained, when it was authenticated, the maximum amount and the collection date.
• The instruction that changed anything — a date change, a bank change, an increase the client accepted. A WhatsApp thread is perfectly good evidence of an instruction, provided it is stored somewhere that survives the consultant who took it. See our debit order entry for the vocabulary insurers use in these exchanges.
• The communications you sent before the collection, particularly for an increase.
• Your opt-in record, because the recovery messages themselves have to be lawful under POPIA and defensible as service rather than marketing.

None of this is exotic. It is the difference between a brokerage that answers a disputed collection in an hour with a link to a thread, and one that spends three days asking a former employee to check their phone.

Frequently asked questions

Does the 60-day rule mean a client can no longer reverse an old debit order?

Through their bank, broadly yes: after the window closes the bank will not process the dispute, and the client is directed to take it up with the biller. That is not the end of the matter — they can still complain to you, to the insurer or to an ombud scheme — but the automatic reversal route is closed.

Is a DebiCheck mandate really harder to dispute?

It is anchored differently. The client authenticated it at their own bank, so the mandate details sit on the bank's side and a dispute has to point at a mismatch, typically in amount or date. An ordinary EFT debit has no such record at the bank, which is why insurers have pushed authenticated collections for years.

How long does the client have to authenticate a new mandate?

It depends on the transaction type your collection partner uses. A real-time request has to be confirmed the same day, a batch request gives the client roughly two days to respond, and a card-and-PIN mandate is confirmed on the spot at a point of sale. Ask your collections provider which one runs on your book before you promise a client that cover restarts tomorrow.

Can we keep messaging a client whose collection failed if they never opted in to marketing?

A message about a specific failed collection on an existing policy is service, not direct marketing, and that is the distinction POPIA cares about. Keep it to the policy, the amount and the options; the moment you add an offer for another product, you are in marketing territory and need the consent to match.

Should our brokerage collect premiums ourselves?

Only with clear eyes. A section 45 authority brings security requirements, monthly returns to the insurer within 15 days of month-end, and full ownership of the reconciliation and the dispute trail. Many brokerages get more value from being excellent at the conversation around a failed collection than from holding the collection file themselves.