Cape Town, South Africa – The Scalabrini Centre of Cape Town (SCCT) has formally submitted written representations on the Draft Revised White Paper on Citizenship, Immigration and Refugee Protection.

The submissions look at and consider the positive aspects of the draft revised white paper including universal birth registration, remaining signatories to the 1951 Refugee Convention and its Protocol without reservation, digitalisation and enhanced efficiency aspects, while making comments and recommendations on areas for improvement.

 

In our submission, SCCT highlights concerns regarding:

 

• The continued denied access to asylum to new asylum applicants through “good cause” interview requirement (currently under consideration by the Constitutional Court);
• The proposed First Safe Country Principle and the real risk of refoulement in its application;
• Relocation of Refugee Reception Offices to ports of entry which is impractical and not in keeping with South Africa’s Urban Refugee Policy;
• The introduction of a Points-Based System for permanent residence for refugees;
• Substantial restrictions affecting section 4(3) citizenship applications for children born in South Africa;
• The merger of RAASA and SCRA and its implications for independence and efficiency;
• Reduced documentation protection and integration safeguards for trafficking survivors;
• The risk of use of civil data within digital systems for immigration enforcement;
• and a needs-based approach to the right to work and study that would undermine constitutional right dignity, as affirmed in the Watchenuka judgment.

 

SCCT further advocates for the expanded use of Alternatives to Detention in immigration enforcement, which are more cost-effective, humane, and promote compliance. We also call on the Department of Home Affairs to explore practical regularisation pathways and visa regimes tailored to low- and medium-skilled regional migration realities.

 

The Scalabrini Centre of Cape Town remains committed to constructive engagement with government to ensure that South Africa’s migration framework upholds constitutional values, human dignity and international protection obligations.

 

SCCT’s Submissions on the Revised White Paper and a summary of the recommendations may be accessed here.