The International Air Transport Association (IATA) notes with concern South Africa’s new immigration measures that came into effect today, including requiring adults travelling with children to carry unabridged birth certificates

As the body representing the majority of the world’s scheduled airlines, IATA and its member airlines want to be a part of the solution that helps reduce instances of the terrible crime of child trafficking.  But it is in everyone’s interests that the measures used to stop the illegal movement of people, do not have unintended side-effects that cause greater harm than good.   

With its experiences working constructively with governments and immigration bodies around the world, IATA has repeatedly offered its support to South Africa’s Dept of Home Affairs with a view to crafting pragmatic and effective controls and processes that would curb illegal movements of people without any negative economic impact or compromising South Africa’s security.

From a commercial and economic perspective, the major worry is that the harsh and onerous requirements South Africa has prescribed for travellers will negatively impact on the sustainability of air services, travel, trade and tourism to, from and via South Africa.  That would undermine the country’s economy – which is already vulnerable and fragile – with serious repercussions that would be felt across the entire sub-Sahara region.

IATA fully supports South Africa in its laudible campaign to combat child trafficking.  But the new measures prompt us to ask just how big the problem is in South Africa?    Is the country dealing with a problem of crisis proportions?   And how much of it takes advantage of airlines serving South Africa’s major international airports?  Airports are not the only points of entry and exit to a country and by the Government’s own admission, its land borders are porous and it has inadequate resources to patrol its long coast line from traffickers and smugglers.  The SA Police Services 2004-2014 crime statistics, which categorises all significant types of reported offences, make no mention of child trafficking.  Can one infer from this that the level of incidence does not warrant the categorisation of such occurrences?

So is the Government using a sledgehammer to crush an ant?  IATA believes there are better and more effective alternative solutions worth exploring.  It is on these burning issues which IATA and its sister bodies in travel and tourism, have sought to engage South Africa’s Department of Home Affairs on since last year. 

Equally worrying for the industry that facilitates trade and tourism, is the lack of information flowing from the departments of Home Affairs and International Relations & Cooperation on the questions surrounding their readiness and ability to apply the new regulations, both with respect to processing visa applications under the new regulations and to effectively enforcing the new measures.  

Airlines and travellers are entitled to answers on this as under the new regulations they face severe penalties and commercial losses if they inadvertently sell tickets to or carry passengers to South Africa who are subsequently denied entry to or exit from South Africa.  Ultimately those risk costs will be shared by all travellers.

Airlines are in the business of safely carrying people and goods between markets.  They are neither policemen nor immigration officers, yet governments, including South Africa’s, insist on passing the buck and tasking airlines with doing governments’ work – with no reward or reimbursement for the additional costs incurred for doing so?    Surely then governments should ensure that everyone in the chain is consulted on the rules, that there is proper and full understanding of them and that their enforcement measures are pragmatic and manageable.

In the sole meeting we were granted with the Minister of Home Affairs last September, we learned that very few South Africa’s foreign missions had been equipped with the new biometric visa equipment and that skills training of the staff at those missions had only recently begun.  Similarly, it became apparent that South Africa only had limited consular representation in key markets such as China and India and that compliance with the new regulations would require people not living in Mumbai, New Delhi and Beijing to undertake two expensive additional journeys to those centres to apply in person for their visas and then to return to collect their visas (or be told their applications were unsuccessful and be given back their passports).

The effects of over-regulation should already be apparent to South Africa which, in 2013, invoked a new transit visa requirement for travellers commuting to and from other African countries on flights connecting at South African airports.  The result has been a marked movement of intra-African connecting passengers away from Johannesburg’s O.R.Tambo International Airport to Nairobi, Addis Ababa and even Dubai, all of which offer comprehensive connections to African destinations with simplified, yet still effective, visa and immigration processes.

Earlier this year South Africa hosted a meeting of AU Transport ministers where they committed to implementing a single common market for African airlines.  An IATA-commissioned econometric study released last year found that the economic benefits of doing so for Africa’s top 12 key markets – which include South Africa – would amount to an additional ZAR18.6 billion in GDP and would create roughly 155,000 additional jobs.   In their current form, South Africa’s new immigration regulations stand as an impediment to this and represent a potentially harmful example of a lack of joined-up and coordinated policy making.

In last September’s meeting with the Hon. Minister of Home Affairs, he agreed to stop the clock on the implementation until 01 June 2015 and to appoint a joint Government-Industry task group to research international best practices and make recommendations on the new regulations and their implementation.  It’s task was also to include the preparation of a communications strategy and toolkit to support the roll-out of the new systems and processes and ensure that accurate and consistent information was conveyed to potential travellers and all other stakeholders.

For reasons unknown to us, and despite several attempts to maintain an open channel with the Minister’s office, this task group was never appointed and none of the tasks undertaken.

Despite these unanswered questions, IATA has every faith that the South African Government is acting in the best interests of the country and that it will review, modify, or, if necessary, rescind, the new measures if they do not have the desired effect and if they act as a handbrake on travel, tourism and economic growth, not just for South Africa - which is experiencing its weakest GDP performance in decades - but for the entire region.