2 September 2026 · Dealers · Gqeberha

Can I keep my register on a computer?

Many dealers keep a paper book because they believe the law requires one. It does not. The real question is not whether you may keep the register on a computer — it is whether you can do three specific things when a police official walks in.

Many second-hand goods dealers keep a paper book because they believe the law requires one. It does not. The Regulations made under the Second-Hand Goods Act contemplate an electronic register openly, and the Act's own definitions do too. The real question is not whether you may keep your register on a computer. It is whether you can do three specific things when a police official walks in.

Ready at the counter, every trading day

This is the short version of what follows, for a dealer who keeps the register on a screen. The first three come out of regulation 8. The last one is our own suggestion, not a legal requirement.

• Someone on the premises who can log in and show the register inside the program.
• A blank disc or similar storage device you can write an export to.
• A system that can produce a current stock-on-hand list, and a printer with paper in it if the official asks for that list on paper.
• A note of every past inspection: the date, and the official's name, number and rank.

What regulation 8(1) actually says

Regulation 8(1) of the Regulations for Dealers and Recyclers, 2012 (GN R285 in GG 35220) reads:

Subject to the provisions of Regulation 9, the register contemplated in section 21(1) of the Act must essentially be in the form and contain the particulars as set out in Annexure "B" to these Regulations.

Note the word essentially. The duty is to be essentially in the form and to contain the particulars. That is not the same as reproducing a printed grid line for line. We have seen no authority telling us how far "essentially" stretches, and we are not going to guess for you. What we can say is that the drafter chose that word instead of "exactly", and that a screen is not obviously excluded by it.

The Act reinforces the point in its definitions. Section 1 defines the term in the plural:

"registers" means registers prescribed in terms of this Act, and includes a print-out of registers kept electronically;

A printout of an electronic register is a register. That wording is repeated almost word for word in the definitions paragraph of SAPS National Instruction 2 of 2016, which we were able to confirm. We could not reliably read the rest of that Instruction — see the end of this page.

Regulation 9 then tells you which Annexure B register applies to you:

A dealer or recycler must keep the applicable register set out in Annexure "B" that corresponds with the description of the principal business activity of that particular dealer or recycler on his or her certificate of registration.

So the form you must follow is the one matching the principal business activity printed on your certificate. A jeweller and a scrap metal dealer are not on the same form. Note also that Annexure B provides a separate acquisition register and a separate disposal register for each dealer type, so most dealers are keeping two, not one — and section 21(3) of the Act requires further separate registers where your certificate of registration carries a condition to that effect. Read the conditions on your own certificate.

A specific warning if you deal in scrap metal or controlled metals. Our sources are the 2009 Act as gazetted and a consolidation stated to be current to 30 April 2012. Scrap metal rules are the part of this area most likely to have changed since then, and we have not checked. Do not treat this page as covering your controlled-metal duties.

The three conditions, and where dealers get caught

Going electronic is permitted. It also attaches conditions that a paper book does not carry. All three sit in regulation 8.

1. The officer must be able to inspect inside the software

Where a dealer or recycler keeps any register in an electronic format, that dealer or recycler must ensure that an inspecting police official may inspect such register through access to the software program with which such electronic register is kept.

On an ordinary Tuesday this means somebody on the premises must be able to open the program and show the register on the screen. Section 28(1) of the Act lets a police official enter the premises of a registered dealer, during times when business activity in respect of second-hand goods is taking place, in order to investigate compliance with the Act, and require production of any register, record, book or other document relating to the goods for inspection.

Two more things about section 28 matter on the day. If the official finds that your method of dealing, of recording transactions in registers, or of storage contravenes the Act, section 28(2) lets him demand immediate discontinuation of that method and afford you a period of no more than seven days to rectify it. And section 28(3) obliges you, your staff and whoever is in charge of the premises to assist him — with an electronic register that means logging in and working the program for him, not pointing at a locked screen.

If the only person who knows the password is on leave, if the laptop is at the owner's house, or if the system will not open without an internet connection that is down, you are relying on an officer's patience rather than on regulation 8(2) being satisfied — and we would not want to argue that you had ensured access. A printout in a folder is a useful thing to have, but regulation 8(2) asks for access to the program itself.

2. The storage device with everything since the last certificate

Where a dealer or recycler keeps registers in an electronic format and in the event of an inspection by a police official in terms of section 28(1) of the Act, the dealer, recycler, owner, employee or person in charge of the premises must -

(a) provide the police official inspecting the register with-

(i) the most recent certificate contemplated in section 28(4)(b)(ii) of the Act; and

(ii) a compact disk or other similar storage device with an electronic copy of or extract from the register reflecting all transactions since the most recent certificate contemplated in (i); and

(b) comply with any reasonable request from such police official to produce a printout of or an extract from the register which reflects the stock that dealer or recycler has on hand at the premises in question.

This is the condition that catches people. It asks for two things you cannot improvise at the counter: the last inspection certificate, and a copy of every transaction recorded since it.

There is an honest difficulty here, and we would rather name it than paper over it. Section 28(4)(b) of the Act says that on each occasion an official inspects a register he must:

(i) sign his or her name immediately after the last entry in that register, and append his or her number and rank and the date on which the inspection was conducted; or

(ii) certify in the manner that the National Commissioner may from time to time direct, that the records were inspected.

Those two are alternatives, joined by "or". Subparagraph (ii) uses the verb "certify" and leaves the manner to the National Commissioner. It does not describe a document. Regulation 8(3)(a)(i) nonetheless calls the result "the most recent certificate contemplated in section 28(4)(b)(ii)". So we cannot tell you what that certificate looks like, or whether you will be handed one at all instead of getting a signature in your book. The two texts do not settle it.

The practical consequence is worth stating: if the official signs your register instead of certifying, there may be no certificate for you to hand over at the next inspection. That is a gap in the texts, not a failure on your part.

Our practical suggestion, which is prudence and not a legal requirement: whichever happens, record the date of every inspection and the official's name, number and rank, and keep that with your records. It gives you a defensible starting date for the "since the last certificate" export. And if you have never been given anything you would call a certificate, do not freeze. Export from the date of the last inspection you have a record of, or from the start of your register if there is none. Say plainly that is what you have done, show the signed entry and the date it carries, and ask the official whether he will sign under your last entry as section 28(4)(b)(i) allows. Ask, do not insist — the Act gives him a choice between signing and certifying in the manner the National Commissioner directs.

The second half of the condition is dated in a way that will irritate you. Regulation 8(3)(a)(ii) asks for "a compact disk or other similar storage device". That was written in 2012. Whether a USB stick, or an emailed file, falls inside "other similar storage device" is an interpretation question the text does not answer. We are not going to tell you a memory stick definitely satisfies it, because the words do not say that. Keep something you can physically hand over.

3. The stock-on-hand printout

Regulation 8(3)(b) lets the official make a reasonable request for a printout of or an extract from the register showing the stock you have on hand at that premises. Note the shape of it: a printout or an extract, on reasonable request. In practice that means a system that can produce a current stock list, not only a transaction history — and, if the official asks for it on paper, a printer that works. Dealers who can produce every purchase since January but cannot produce a list of what is on the shelf right now are the ones who struggle here.

What going electronic does not change

Section 21(7) of the Act requires every entry to be made contemporaneously with the acquisition or disposal. A computer does not buy you the evening to catch up.

Section 21(4) requires the customer to hand you an original identity document or passport. A photo on a phone, a WhatsApp image or an emailed scan does not satisfy it, no matter how neatly your system files it. Section 21(5) then requires you to obtain and keep a copy of the original you were shown, which is separate again from typing the ID number into a field. We should add one honest caveat: regulation 8 permits an electronic register, and says nothing either way about whether the section 21(5) ID copy may be kept electronically instead of on paper. We could not verify that point. If you want to be safe, keep the paper copy as well.

And section 21(6) requires you to retain the register and those copies for not less than five years, calculated from the date of the relevant transaction. Note where that rule lives: it is in the Act, not the Regulations. Anyone citing "the regulations" for the five-year period is citing the wrong instrument.

What Dot Book does about this

One thing to settle before you put a register of other people's identity details onto anybody's software. Your register holds sellers' names, addresses and identity numbers, and copies of their identity documents. Under POPIA you are the responsible party for all of that. If you hand it to a vendor who stores or processes it for you, that vendor is an operator, and section 21(1) of POPIA requires a written contract between you and them ensuring they establish and maintain the security measures in section 19.

Note carefully where that duty sits. It is phrased as a duty on you. If your register is sitting on a vendor's server and there is no signed agreement, the person in breach is you, not the vendor. So: before you load a single customer's identity document into any cloud system, ask that vendor for the operator agreement in writing. If they do not know what you are asking for, that is your answer.

Dot Book's dealer edition is built the other way round. The register stays on your own device. It is not uploaded, we cannot read it, and it opens with the internet off — which also disposes of the regulation 8(2) worry above, because there is no connection to lose. We think that means the operator question does not arise for your register at all, since we never hold it. We would rather say that carefully than confidently: it is our reading of our own architecture, not a legal opinion, and if you host anything of yours with anybody — us included — for any other purpose, get the agreement.

Dot Book does not make you compliant. No software does, and any vendor who tells you otherwise is selling you a feeling. What it does is mechanical.

It stamps each entry with the date and time at the moment your staff save it. Be clear about what that does and does not do. It does not make the entry contemporaneous — only capturing the deal at the counter does that. Section 21(7) still requires contemporaneous entry, and section 21(2)(f) requires the date and time of the transaction itself, which must be captured accurately whether or not it matches the save time. What the stamp does is record, permanently, when the entry was actually made, which means late capture shows up plainly to anyone inspecting. Used properly that is a discipline; used carelessly it is evidence against you.

It opens on the shop machine so an official can be shown the register inside the program. We raised the connection problem above, so we should answer it for our own software rather than dodge it: the dealer edition runs on your device and opens with the internet off. Your data lives on your counter. Ask any vendor the same two questions before you sign — will it open and display the full register with the connection down, and where does the data physically live — and get the answer in writing, not in a sales conversation.

It exports every transaction between two dates you choose, to a file you can write to a disc or a device. It prints a stock-on-hand list for the premises.

It keeps the identity copy attached to the entry it belongs to, and it does not delete entries on its own — corrections are struck through with who changed them, when, and why. A register with no missing lines is worth more than a tidy one.

What that does not cover is the case that matters most. The five-year retention duty in section 21(6) is yours, not ours. It covers both the register and the identity copies, and it outlives any software. Because the dealer edition sits on your device, your records do not disappear if you stop being a customer — but your device can be stolen, dropped or burnt, and the duty does not care. Take a full export you can keep somewhere else, in a form you can read without our software, and do it on a schedule rather than when you remember.

Two of the three things regulation 8(3) asks for are outputs a system can generate: the export of transactions for a date range, and the stock-on-hand list. The third — the most recent certificate contemplated in section 28(4)(b)(ii) — comes from the police official, not from us, and no software can produce it for you. Keep whatever you are given, or your own record of each inspection, with your books. And if your staff do not capture the particulars, or capture them wrongly, none of this helps you. Filling it in correctly is still your job.

What we could not verify

This is the part most guides leave out.

• The Annexure B column headings. We could not read them reliably. The gazette PDF has a machine-read text layer, but the register tables extract with their columns scrambled and their order lost, complete with obvious errors ("SOLO" for SOLD, "Mbnner" for Manner). We can confirm that Annexure B contains an acquisition and a disposal register for each of five dealer types, and we can confirm some field labels. We cannot state the column list or its order. So we are not publishing a register template, and you should treat any template you are offered with caution unless the person offering it has read the printed gazette. That caution applies to us too. We have not been able to read the Annexure B tables in the gazette PDF, so we cannot tell you our own field layout matches them column for column. If your register form matters to your local station — and it can — check our layout against the printed gazette or your certificate conditions before you rely on it. Getting the columns wrong is not a cosmetic error: regulation 8(1) ties your register to that form.
• Whether the 2012 Regulations or the Act have been amended since. Our copies of the Act are the 2009 text as gazetted and a consolidation stated to be updated to 30 April 2012. We did not establish whether later amendments, including scrap-metal amendments, changed section 21, the definitions, or these regulations. Check the current in-force text before you rely on any of this.
• Penalties for breaching regulation 8(3). One reading of regulation 15 suggests that failing to produce the certificate, the storage device or the stock printout is an offence. We could not corroborate that reading, so we are not stating it as law. For what it is worth, that same uncorroborated reading would make it an offence carrying a fine or imprisonment not exceeding 12 months. We are giving you the figure so you can judge the risk yourself, not asserting it as law. Separately, the Act carries criminal penalties of its own. Section 32(2) provides that a person convicted of a contravention of or a failure to comply with any section mentioned in Column 1 of Schedule 3 may be sentenced to a fine, or to imprisonment for a period not exceeding the period mentioned in Column 2 opposite that section, or to both. We have not verified which rows of Schedule 3 name section 21, so read the Schedule rather than taking a number from us. The point is that these are duties with criminal penalties standing behind them, not housekeeping.
• What SAPS National Instruction 2 of 2016 says about registers. We could confirm its definition of "registers", which tracks the Act almost word for word. We could not retrieve its body text reliably enough to quote. It may add operational detail on electronic registers that is not in the Act or the Regulations. If your local station works to it, ask them.
• The source text itself. Every quotation above came from official online copies of the Act and the Regulations rather than from the printed gazette in front of us. We are confident in the substance. We are less confident about punctuation, and about one numbering oddity in the annexures. If a citation is going to be argued over, read the gazette.

Other guides on this site

These apply whether you keep your records on paper or on a screen. Free, no sign-up, no email required.

• Seven days, or seven working days? — how the holding period in section 23(1)(d) is actually counted, why Saturdays count, and the exception that was repealed in 2009 and that a lot of yards still rely on.
• The seven-day rule that catches repair shops out — who the Act actually reaches, which is wider than most people assume, and what the register has to contain.

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