Circular 47 of 2025: The CMS’ position on scheme credit card usage

With regard to the prohibition of medical schemes borrowing money or encumbering its assets, specifically in relation to a scheme’s credit card facilities in terms of Section 35(6) of the Medical Schemes Act (131 of 1998) (MSA).

After careful consideration of the relevant provisions of the MSA, the Council for Medical Schemes (CMS), through its Exco Committee, resolved in a meeting held on 28 November 2025 that:

1. Section 35(6) of the MSA prohibits a medical scheme from borrowing money or giving security without prior approval from the CMS. The purpose of this provision is to safeguard the financial integrity of schemes by preventing debt obligations that could compromise solvency.

2. A credit card facility does not constitute borrowing within the meaning of Section 35(6), provided that the usage of a scheme credit card:

• Is governed by a board-approved policy specifying permissible use;
• Is used solely as a payment mechanism for approved expenditure; and
• Is fully settled at month-end, ensuring no interest accrues and no long-term debt obligation arises.

Section 8(h) empowers the CMS to grant exemptions from provisions of the MSA in exceptional circumstances. However, as a credit card facility meeting the above requirements does not fall within the borrowing prohibition under Section 35(6), an exemption under Section 8(h) will therefore not be required.

Should schemes require any further clarification or assistance, please do not hesitate to contact Mr John Letsoalo at j.letsoalo@medicalschemes.co.za.

Download the full Circular here.