The Section 22 Committee did not
appear out of nowhere in 2025. The Commission recommended registration, umbrella bodies and peer-review committees in its
2017 report to Parliament, and its own legal unit was drafting Bills to regulate the registration of churches and
ministers a year before that. The trail then runs through COVID – where the state showed what it could do to worship
with no registration law at all – to the 2024 conference whose resolutions are not held in this corpus, and into the
Section 22 process six months later. Every row below is rooted in a held primary or official record, or in a clearly attributed parliamentary meeting record, reputable publication or named-witness recording.
| Date | What the record shows | Source |
| 2015–2017 | CRL investigation into the "commercialisation of religion and abuse of people's belief systems" – hearings, a preliminary report, and a 28 February 2017 deadline for comment. The start of the documented campaign. | CRL final report (2017) |
| 25 Oct 2016 | The earliest held direct statement of the licensing project in the Chairperson's own voice: "We need a new legal framework… every church or religious institution in the country is truly registered… every practising practitioner, a religious practitioner, must be licensed. We are saying that licence is not a right, it's a privilege, it can be withdrawn." | SABC, 25 Oct 2016 ↗ @09:19 |
Oct 2016 preliminary report | The Commission's preliminary report already sets out a licensing architecture (§§17, 18.2, 18.6, 18.7). Superseded by the 2017 final report; shown here because it dates the architecture a year earlier. | CRL preliminary report 2016, pp. 31–37 |
| 2016/17 financial year | The Commission's legal unit drafted five amendment Bills, two of them "to regulate the registration of religious organisations, including churches, and ministers of religion" – via the CRL Act, or alternatively the Non-Profit Organisations Act or the Marriage Act. This supports an inference that the Commission was exploring additional statutory authority. Bounded: the Bills have not been located in Parliament's bill tracker, the Gazette, the CRL website or 217 archived CRL PDFs, so their text, introduction and status are not established. Not-found, not not-there. | CRL Annual Report 2016/17, Part B §3.2 |
| 2017 final report | The Commission recommends it issue registration certificates on the advice of peer-review committees, with every worship centre and practitioner attached to an umbrella structure. | CRL final report, pp. 44–46 |
| 2017 final report | Registration would determine whether an institution may operate: the peer-review committee advises, and "the final decision powers shall lie with the CRL Rights Commission." The Commission's own framing, carried in the same breath: certificates would be issued by itself in consultation with umbrella bodies, "and not by the State or Government" – though the CRL is a Chapter 9 body established by statute. A 2017 proposal, never enacted. | CRL final report, §§19.3–19.4 |
| 2017 final report | The report argues religious practitioners should be regulated as professionals: "the proposal to regulate the religious institutions and practitioners as professionals is in line with the Constitution and the Bill of Rights." The Commission's assertion, not an adjudication – no court has held that ministry is a profession in law. | CRL final report – our copy is byte-identical to the parliamentary tabled copy |
| 27 Jun 2017 | The Commission presents its findings and recommendations to Parliament's COGTA Portfolio Committee at a workshop. | COGTA committee report |
| 17–18 Oct 2017 | COGTA receives submissions from the religious sector on the CRL's proposals. | PMG hearing record ↗ |
| 2017/18 financial year | In a report tabled to Parliament, the Commission presses the profession analogy to its conclusion: "If all other professions are subjected to a form of regulation, why not the religious sector. If a teacher can be punished and struck off the roll, why is it difficult for religious leaders to be subjected to the same?" The same report prints, unanswered, the objection put to it: "What will happen to a pastor who does not want to belong to a fraternal or an umbrella organisation?" | CRL Annual Report 2017/18, Part B |
| 14 Feb 2018 | The COGTA Portfolio Committee adopts its report. It records the sector's objections – insufficient consultation, disputed constitutionality, and that "the CRL Rights Commission is not the body that should be regulating the sector" – and recommends legislation anyway: a sector code recognised by legislation, and strengthening laws "like the Non-Profit Organisation Act and the Income Tax Act to ensure registration of religious institutions." A portfolio committee, not Parliament as a whole; tabled to the National Assembly for consideration. | ATC, 14 Feb 2018 |
| 29 Oct 2018 | CRL CEO Edward Mafadza tells eNCA that government must maintain an orderly country and "we want to be like other countries." The speaker is the Commission's CEO. | eNCA interview ↗ @03:13 |
| 13 Feb 2019 | Opening the National Religious Summit, the Chairperson warns that if religious leaders do not take responsibility, government will do it for them – then: "Look at what has happened in other countries." Gateway News reported this contemporaneously; IIRF reproduced a transcript derived from contemporaneous audio in 2025. The direct tape is not held. | IIRF report ↗ p.9; Gateway News ↗ |
| 24 Feb 2019 | In an addendum to the 2017 report the Commission states that if the problems continue government will impose itself, and that "the CRL Rights Act already gives the CRL Commission the right to establish a register" – the proposed changes being "a realisation of the existing powers." Bounded: the Act authorised a register of cultural, religious and linguistic communities and funding for Community Councils. That database/recognition power is not identical to the compulsory institution/practitioner registration proposed elsewhere; at most the documents create a legal and policy tension with the 2016/17 Bills above. | CRL addendum, 24 Feb 2019 |
| 2019/20 financial year | The Commission's annual report shows limited continuity — regulation-related discussion persists in the reporting period. A bounded held-record finding; no claim is made about its wider public activity. | CRL Annual Report 2019/20, pp. 15, 59 |
| 2020–2021 | Under the Disaster Management Act the state demonstrates what it can do to worship with no church-registration law in existence: in-person worship banned by regulation, singing, baptism and the Lord's Supper prohibited, 465,098 people arrested by June 2021. Context, not a CRL event – covered in full under COVID – Force vs Worship in the rail to the left. The Commission's 2019/20 annual report continues to discuss regulation; no claim is made here about its public activity in this period. | COVID Enforcement Exhibit |
Dec 2022 published by May 2023 | The database power is operationalised. CRL Form A001R requests umbrella-body, NPO and constitution data, and requires five leaders plus a board resolution to apply for recognition. File dated Dec 2022; hosted in the CRL's May 2023 uploads directory. The exact public upload date is not established. This is the community database/recognition power — not compulsory institution or practitioner licensing. | CRL database registration form A001R |
| 25–27 Jun 2024 | The Commission holds its statutory Fifth National Consultative Conference for cultural, religious and linguistic communities generally (CRL Act §§24–25), themed "30 Years into Democracy". The annual report records that resolutions were adopted and reported. Bounded: the resolutions' contents and the 28 June 2024 media statement are not held in this corpus. Whether this was the religion-sector conference recommended in the 2018 COGTA report is not established. | CRL Annual Report 2024/25 |
| Date | What the record shows | Source |
| 13 Dec 2024 | President Ramaphosa appoints the CRL commissioners "for a period of five years" and, under §12 of the CRL Rights Act, appoints Mkhwanazi-Xaluva as Chairperson. Supports an inference of leadership continuity into 2029. | The Presidency, 13 Dec 2024 |
| 6 & 11 Feb 2025 | A CRL plenary decision records the purpose as "(Regulation of Religious Leaders)". On 11 February the Commission issues an official statement limiting how that decision should be read. Both in the Commission's own 21 Jan 2026 press pack. | CRL press-conference documents, 21 Jan 2026, pp. 11, 22–23 |
| 12 Feb 2025 | Two months before the Committee chair's formal appointment and the April launch, the Chairperson states the legislative purpose on Newzroom Afrika: application, licence and suspension or removal; the doctor analogy; and legislation through Parliament via a Section 22 committee. | Newzroom Afrika, 12 Feb 2025 ↗ @06:05–09:28 |
| 21 Feb 2025 | At a CRL press conference the Chairperson describes registration and licensing of religious leaders, grounded in §22. Bounding, from the same answer: she frames the proposal as directed at leaders' conduct rather than at how, whom or why people worship. | CRL press conference, 21 Feb 2025 ↗ @08:58–11:27 |
| 15 Apr 2025 | The Commission launches a peer-review mechanism / Section 22 Committee for the Christian sector. Its mandate as stated that day is a "legal and/or legislated framework" and peer review – the terms registration of institutions and registration of practitioners are absent from it and from the 6 Feb 2025 plenary minutes and 25 Apr 2025 appointment letters. Regulatory purpose is on the record: the plenary minute is glossed "(Regulation of Religious Leaders)", and the Chair described registration and licensing publicly in February and April. | CRL media statement, 15 Apr 2025 ↗ |
| 16 Apr 2025 | The day after the launch, the Chairperson describes a legal framework, registration and vetting of churches and leaders, minimum standards, and the state having "lost control" and needing to "get back control". | Newzroom Afrika, 16 Apr 2025 ↗ @01:17–09:30 |
| 23 Jun 2025 | A signed Terms of Reference expands the Committee's brief to registration. Clause 6.1.1 tasks it with "development of the legislative framework" providing for (a) a Religious Practice Council, (b) registration of religious institutions, (c) registration of religious practitioners. This is the first located Section 22 committee instrument expressly tasking the committee with a Council and with registration of institutions and practitioners. It is not the first CRL registration proposal — see 2016/17 and the 2017 report above. Bounded: not the first appearance of registration in CRL thinking – it was Commission policy from 2016/17 (see Phase 1). Registration entered the Section 22 instruments between April and June 2025. | Signed ToR, 23 Jun 2025 ↗ §6.1.1 |
| 2 Oct 2025 | The committee constituted under §22 of the CRL Rights Commission Act is formally launched: "Section 22 … was formally launched on October 2, 2025." Committee chair Rev. Prof. Musa Xulu later stated that at the launch he was handed a revised signed ToR he had "never seen" and read its legislative-framework and registration items into the public record. | Launch statement; account: Xulu on camera, 15 Jan 2026 ↗ @18:55 |
| 19 Dec 2025 | The committee publishes a draft voluntary self-regulatory framework for national consultation. It proposes an independent Christian Practice Council for Ethics and Accountability, a public register of organisations that adopt the framework, complaint investigation, and sanctions up to loss of the seal, deregistration and public notice (§§6.1–6.3, 7.1). The document calls itself voluntary and "not state control". In the same-day Q&A the Chairperson puts both halves in her own words. She says "the voluntary part is about participating in the section 22" – and then: "The ultimate aim will have to be, if you want to operate in this country as a church… We are saying it's not going to be optional at the end of the day. So springing up will not be an option at all." | CRL draft framework (2025); Q&A: CRL press conference, 19 Dec 2025, IYHKYpbHCQk @01:01:10–01:02:10 |
| 22 Dec 2025 | The model is noted to echo China's system of state-controlled "patriotic associations" – each umbrella body controlled by the CRL, effectively nationalising religion under state supervision. Independent analysis by Bitter Winter / M. Introvigne – not a CRL Chair quote, and not attributable to her. | Bitter Winter, 22 Dec 2025 |
| 15 Jan 2026 | The Commission's own appointed Christian-sector chair resigns. Rev. Prof. Musa Xulu quits as Chair of the Section 22 Committee: "I can no longer serve as Chair of a Committee the processes of which I do not control, the outcomes of which I do not endorse, and the existence of which is being used as a front to disguise a predetermined agenda of State control of religion, driven in part by personal hostility toward particular Christian faith and traditions." He adds that "entire sectors of Christianity, particularly Pentecostal and Charismatic churches, were treated with open suspicion and hostility." | Mail & Guardian ↗; Gateway News ↗ (statement dated 15 Jan; reported 16 Jan) |
| 15 & 21 Jan 2026 | The Commission's answer. On 15 January the remaining Section 22 members state that Xulu's briefing "does not represent the collective views, position, or mandate of the Committee" and that his statements are "personal opinions", the media invitation having been circulated "without the Committee members' knowledge". On 21 January the CRL rejects a compulsory state-licensing characterisation, calls the framework voluntary and sector-led, and publishes its own chronology. | S22 Committee clarification, 15 Jan 2026; CRL press-conference documents, 21 Jan 2026 |
| 11 Feb 2026 | Religious leaders ask Parliament to investigate the Chairperson. A letter to the Speaker of the National Assembly requests an investigation under §17 of the CRL Rights Act on three grounds: public statements said to be "misleading, disrespectful to religious beliefs, divisive, intimidating and discriminatory" and to propose extending CRL powers "to enable it to authorise or prohibit religious practitioners" beyond the Commission's constitutional mandate under §185; Xulu's allegations of interference; and conduct said to undermine the Commission's own credibility contrary to §15. They state they "attempted unsuccessfully to engage with the Chair directly", that "the S22 committee should be disbanded", and that as Christian leaders they "reject any special laws or regulations or state structures to regulate religious practitioners or church institutions." Signatories include the African Religious & Traditional Leaders Council, the Khayelitsha Development Forum Religious Forum, Without Walls Apostolic Ministries Network, Christian View Network and Concerned Christians. | Letter to the Speaker of the National Assembly, 11 Feb 2026 (tabled to COGTA 31 Mar 2026) |
| 24 Feb 2026 | The Commission reiterates the call, on its own letterhead: the religious sector "requires a self-regulatory council" – like the bodies that license doctors and lawyers – involving "the registration of pastors, vetting … and adherence to a code of conduct." | CRL statement, 24 Feb 2026 (image + transcript) |
25 Mar 2026 and 2 Apr | The committee publishes a roadmap – nine provincial consultations through April 2027 and a May 2027 national summit, then submission to the CRL and Parliament, stating that the proposed Christian Practice Council for Ethics and Accountability would not be a state body and that organisations would voluntarily adopt the framework. On 2 April the Chairperson states the legislative endpoint directly: "there must be a council for the religious sector, which will then mean there must be an act and a council formed out of that act. You have a council for lawyers, for doctors, for everyone." She cites the Traditional Health Practitioners Act as precedent — "Parliament has passed a similar act for traditional health practitioners and there wasn't this kind of noise about freedom of religion" — and says the Section 22 committee will consult "on two things: on a code of conduct and a peer review mechanism." | S22 media statement, Mar 2026; SABC News, 2 Apr 2026 ↗ @09:09–10:44 — AV mirrored and hashed 18 Aug 2026 |
| 28 Mar 2026 | The Section 22 model is extended beyond the Christian sector: on 24 March the Commission announced, and on 28 March held, a consultative meeting with Hindu religious leaders. | CRL media statement on the Hindu consultative meetings, 28 Mar 2026 |
| 31 Mar & 1 Apr 2026 | The religious sector takes its objections to Parliament. Submissions converge on three themes: alleged misleading of Parliament, overreach of the Commission's constitutional mandate, and divisive public conduct. Complainants argue the founding mandate was to investigate abuses after the fact, not to govern who may practise as a religious leader. One submission alleges the Chairperson publicly claimed a mandate from the 2018 Portfolio Committee process that was never granted. Speakers call for a formal inquiry into her conduct and suspension of the Section 22 process pending it. The tabled letter formally requests an inquiry — and, conditionally, removal. Signed by Philip Rosenthal for leaders "representing Christian churches, religious formations, traditional leadership bodies, advocacy groups and community structures in the Western Cape", it asks COGTA to enquire "in terms of S17(1) of the CRL Act and S194(1) of the Constitution" whether her conduct meets §15 of the CRL Act — and, if she is found in contravention, requests "a recommendation to be made to the President for her removal in terms of S17 of the CRL Act and S194(2)b of the Constitution." It attaches an earlier letter to the Speaker of the National Assembly dated 11 February 2026. | Letter to the COGTA Portfolio Committee, 31 Mar 2026 (scan, OCR'd and eye-verified); PMG COGTA meetings 31 Mar & 1 Apr 2026 |
| 15–17 May 2026 | Four months after resigning, he turns whistle-blower. In a sworn affidavit (15 May 2026) and press statement (17 May 2026), Xulu stated he was contacted by a person claiming to act for the National Intelligence Agency / State Security Agency, and that Christian bodies opposing the CRL – including FOR SA and the SA Church Defenders – had allegedly been referred to the State's security structures for investigation and surveillance. The held National Security Strategy 2024–2028 lists "Mushrooming of charismatic churches" among threats/challenges, and separately attributes a body passage to the CRL's 2017 findings. Sworn allegations; the deponent states he cannot independently verify the caller's identity. | Affidavit summary & public sources |
| 18–19 May 2026 | The Commission's response, and Parliament's scrutiny. The CRL denies targeting religious bodies but acknowledges referring an information breach to the SSA, whose investigation it says is pending. The next day's COGTA hearing scrutinises mandate, legality and inclusivity. The Chairperson's Rwanda denial there is narrow – it concerns mandated buildings, paved parking and window requirements: "we're far away from that." | CRL breach statement; PMG/YouTube hearing, 19 May 2026 @~03:23:18–03:23:47 — held VTT and cleaned transcript; excerpt independently checked 18 Aug 2026 |
| 26 May 2026 | Parliament hears the sector directly. A significant number of presenters affiliated to the International Federation of Christian Churches – including representatives of the Christian Revival Church and the Apostolic Faith Mission, and Bishop Mosa Sono – support accountability but warn that the Section 22 process risks state regulation of religion. The hearing was not unanimous; supportive presenters were also recorded. They argue the Commission effectively selected the committee's own members rather than letting the sector do so, and that the terms of reference contain references to regulation inconsistent with the Commission's stated intention of facilitating self-regulation. | PMG, COGTA meeting 26 May 2026 |
| 24 Jun 2026 | The COGTA Portfolio Committee sets conditions – and contemplates recusal. Committee-level; not a resolution of the House. Members support a code of ethical conduct developed through a more inclusive and representative Section 22 Committee, and agree that any legislative reform should follow only once the code is finalised. A legal opinion is to be obtained before final decisions. The Chairperson of the Portfolio Committee is authorised to engage the Speaker and the CRL to pursue a mediated solution, including the possible recusal of the CRL chairperson from the Section 22 process. | PMG, COGTA meeting 24 Jun 2026 |
| 4 Aug 2026 | The COGTA Portfolio Committee directs interim changes while considering its draft report. The COGTA Portfolio Committee gives the Commission one week to present a plan on Section 22 reform and inclusivity, and directs that the religious sector, not the Commission, must lead the code-of-conduct process. Committee Chairperson Dr Zweli Mkhize: "The Commission should not lead this process or participate directly in the substantive discussions around its content… We must make it clear publicly that the processes are to be separated in this manner." He adds: "The issue of inclusivity has to be addressed. And the issue of reforming the committee has to be addressed." The Committee provides for a forum under §181(3) of the Constitution to assist and protect the Commission, and records that the Section 22 committee "will have to be reviewed and reformed".
The Committee's statement also records: "An application is before the courts to declare the Section 22 process unlawful." The application's identity and current status are not established. The DA did not support the Committee's recommendations, calling for the Section 22 process to be paused pending the court cases and for an independent body to investigate the Commission's Chairperson; the ACDP reserved its position. In its own tabled response the Commission states: "The Commission has never sought, nor does it possess, any mandate to regulate religion", and its presentation describes a "peer-review mechanism, not state regulation", with a final consulted framework planned for May 2027. | COGTA media statement, 4 Aug 2026 (tabled); CRL response & presentation to the Portfolio Committee. Full meeting video and captions held (PMG/YouTube ↗) |
Committee member · 3 seats
Zion Christian Church (ZCC) – est. 1924
SA's largest church (millions of members) – classified by SAHO and scholars as an African Initiated Church whose doctrine "syncretiz[es] traditional African religions and Christian theology." Closed before the lockdown required it, refused to reopen at Level 3, extended its closure far beyond the law; both bishops were publicly vaccinated.
Committee member · 9 seats
Nazareth Baptist Church (Shembe) – est. 1910/11
Classified as the largest African Initiated Church "rooted in Zulu tradition" – scholars document ancestral veneration (impepho incense to invoke ancestors) and a Zulu-dance liturgy. Four factions (Ebuhleni, Gauteng, Ginyezinye, Thembezinhle) hold nine of the nineteen seats; all stayed closed and refused to reopen when legally permitted.
Committee member · host venue
Rhema Bible Church (McCauley)
Charismatic megachurch. Closed immediately on the government's announcement, stayed shut seven weeks past the permitted reopening, and hosted the Section 22 Committee launch at its Johannesburg auditorium.
Committee member
SA Council of Churches (SACC)
Helped design the compliance framework. "The first to call for a lockdown," met President Ramaphosa and cabinet on 26 March 2020, issued guidelines for 30 member bodies, and declared "churches are not exempt from the law of the land."
Committee member
The Evangelical Alliance of SA (TEASA)
Represents ~4.4 million evangelicals. Published its own COVID compliance guidelines and required designated compliance officers for member churches.
Committee member
Council of African Independent Churches (CAIC)
Umbrella body for African-initiated churches. Complied with the worship restrictions throughout the lockdown period.
Committee member
The Great Commission (Western Cape)
A ministers' network. Complied with lockdown worship restrictions; no record of defiance or enforcement.
Committee member
Moral Regeneration Movement (MRM)
Described in reporting as "the first state-sponsored attempt to align South African churches with ANC political doctrines." As an ANC-aligned body, COVID compliance was never in question.
The contrast
Orthodox biblical Christians – structurally unable to comply
Believers who hold to Scripture as final authority, no state licence over ministry and no surrender of conscience cannot meet the implicit qualification – a clergy to license, a registered body, an umbrella organisation able to issue compliance instructions. They could not participate in a state-cooperative framework even if they wished to: not unwilling, but as a matter of conscience. They hold no seat on the committee, yet are subject to its authority.