Independent citizen review · Buffalo City Metropolitan Municipality · kuGompo

BCMM Tariff Red Flags 2027/28

We read all ten documents in BCMM's draft 2027/28 electricity tariff pack. We checked their numbers against BCMM's own earlier tariff books. We found 24 problems that residents should raise before the comment deadline.

Comments close 1 December 2026 · proposed average increase 12.5% from 1 July 2027
Make your submission Request records (PAIA / POPIA)
Reviewed: 7 November 2026 Pack published by BCMM: 30 October 2026 All rand figures exclude VAT unless stated
Bottom line

Most of this increase is the cost of BCMM's own failures

BCMM's notice tells residents that when Eskom's prices rise, ours must follow. Eskom's proposed 8.01% increase only applies to Eskom's share of costs, which is 64%. On that share it explains about 5.1 of the 12.5 percentage points. By BCMM's own figures, the next largest driver is unpaid bills: about 10 points come from bad debt that paying customers are made to cover. Electricity losses have gone up three years in a row. The pack also shows illegal over-billing, charges never billed, numbers that change from one draft to the next, and a public notice with no working way to comment.

5.1 ptsof the 12.5% that Eskom's increase explains (8.01% × 64% share)
≈10 ptsfrom R312m of bad debt that paying customers cover
37.7%of electricity lost, July–August 2026 (20.4% in 2023/24)
R51.0movercharged to small businesses on Scale 2A, above the tariff NERSA approved

The ten flags that matter most

  1. In November 2025 a court declared unconstitutional the council resolution that brought in the monthly basic charge on prepaid homes. The pack doesn't mention the ruling, yet it raises the charge again, to R497.93.
  2. You can't comment through the channels the notice gives. The survey link, email address, postal address, meeting dates and hotline all still read [to be inserted].
  3. Small businesses on Scale 2A were billed 36% more than NERSA approved (R51.0m). BCMM now proposes a 27.5% increase for the same customers.
  4. About 10 points of the increase is unpaid debt that paying customers cover. The pack doesn't say who owes it.
  5. A R102.1m "loss on disposal of assets" is included in the costs that tariffs must recover. It is worth about 3.4 points.
  6. Losses are getting worse: 20.4% in 2023/24, 32.3% in 2025/26, and 37.7% in July–August 2026.
  7. Losses jumped in the same year the prepaid basic charge began (2024/25). The pack never asks whether the charge played a part.
  8. Prepaid homes already pay R118.7m a year more than it costs to supply them.
  9. A R7,000 penalty is payable upfront by a target group that includes meters that simply stopped buying or are faulty.
  10. The core study is marked DRAFT FOR INTERNAL REVIEW. NOT FOR SUBMISSION, went through eight versions in six days, and relies on billing data BCMM says is wrong.

Each flag below gives the document and page number as F01–F11, the numbers BCMM gives its own files. A red flag is a problem that needs answering. It is not proof of corruption. Several of these items do call for an independent investigation, and the questions at the end are written so that Council and NERSA have to answer them on the record.

What it means for a household

A prepaid home's bill has nearly doubled in four years

Until 2023/24, prepaid homes on Scale 1B paid only for the units they bought. A monthly basic charge started in 2024/25. It is billed to your municipal account even if you buy no electricity. The chart shows a home that uses 300 kWh a month, with the losses BCMM reported for the same year.

LOSSES R0 R500 R1,000 R1,500 2023/24 basic R0 R866.68 20.4% 2024/25 basic R376 R1,177.00 32.2% 2025/26 basic R423.90 R1,326.90 32.3% 2026/27 basic R461 R1,471.40 37.7%* 2027/28 basic R497.93 R1,589 ?
Scale 1B prepaid, 300 kWh a month, excluding VAT. Sources: BCMM tariff books 2023/24, 2025/26 and 2026/27, and draft 2027/28 (F03 p7). Losses from F04 p27–28. *July–August 2026 only. 2027/28 is proposed. That is +83% since 2023/24. At 200 kWh a month the bill rises 112%, from R577.78 to R1,225.53.
Household (draft 2027/28)UseNowProposedChange
Prepaid home, low use (1B)200 kWhR1,134.60R1,225.53+8.0% · R6.13 per kWh effective
Prepaid home (1B)400 kWhR1,808.20R1,953.13+8.0%
Indigent household (1C)300 kWhR715.00R758.00+6.0%
Rooftop-solar home, imports 100 kWh100 kWhR902.80R1,174.47+30.1%
Small business, 3-phase credit (2A)2,000 kWhR8,912.00R11,362.00+27.5%

Sources: F11 p1 and p6, and F03 p7 and p14. The solar-home figure uses the current Scale 1A rate and the proposed Option A rate.

Findings · Critical

Legality, process and money that doesn't add up

01
Critical · legality

A court ruled against the basic charge on prepaid homes, and the pack raises it again without saying so

The pack says
Scale 1B's monthly basic charge rises from R461.00 to R497.93. It is billed monthly on your municipal account, also for prepaid meters. F03 p7; F11 p4
Context
In November 2025 the Bhisho High Court declared unconstitutional BCMM's 2024 council resolution that brought in the basic electricity charges. BCMM is appealing. We could not confirm whether the appeal has been decided. None of the ten documents mentions the case.
Why it matters
About 75,000 prepaid homes and small businesses would pay R5,975 a year (R6,871 with VAT) before buying a single unit. Residents asked to comment are not told the charge is in dispute in court.
Demand
Disclose the status of the case and what the appeal is costing. Freeze the basic charge until the appeal is decided, and explain how customers will be refunded if BCMM loses.
02
Critical · consultation

The public notice gives no working way to comment

The pack says
complete the short online survey at [survey link]. Email: [tariff comments email address]. Post: [postal address]. Ward meetings: [dates and venues to be inserted]. Hotline: [hotline to be inserted]. F01 p1, p6, p7; F03 p25
Why it matters
The 30-day window opened on 1 November 2026 with these channels still blank. The comment summary will be sent to NERSA as evidence of consultation (F02 p6). Residents' groups have argued in court that BCMM's earlier tariff consultation was flawed.
Demand
Republish the notice with every channel filled in. Extend the deadline by the number of days it was incomplete. Hold ward meetings in every region, with documents in isiXhosa and English.
03
Critical · unlawful billing

Small businesses were overcharged R51m, and now face a 27.5% increase

The pack says
Customers on Scale 2A were billed R192.3m against R141.3m at approved tariffs, which is 36% more. The study then argues that against actual billing the step looks smaller for customers than the table suggests, about 17%. A refund comes only if confirmed. F04 p9, p13, p19
Why it matters
The Electricity Regulation Act (s15(2)) bars charging any tariff NERSA has not approved, and the pack quotes that section itself (F04 p20). The overcharge averages about R21,300 for each of the 2,396 customers on 2A. These are shops, workshops and larger homes. Pointing to the illegal bills to make a 27.5% increase look smaller rewards the error.
Demand
Refund every affected customer with interest, whatever the outcome of the "check". Name the cause and who was responsible. Phase in or cap the 2A increase until the refunds are paid.
04
Critical · paying for non-payment

Paying customers cover R312m of unpaid bills, about 10 points of the increase

The pack says
Bad debt is included in tariffs, so paying customers carry it. The normalised R312m … adds about 10 percentage points. The actual write-down for 2025/26 was R475.7m. F04 p3, p6, p11
Why it matters
BCMM's own rule of thumb is that each percentage point costs a 400 kWh household about R15.60 a month (F04 p23). On that basis, other people's unpaid bills add about R156 a month to a 400 kWh household. The pack doesn't say who the debtors are: government departments, large businesses, or anyone else.
Demand
Publish an age analysis of electricity debt by customer type: national and provincial departments, state entities, businesses, households, and municipal properties. Publish the top 50 debtors. Confirm that no councillor or official is in arrears; the Councillors' Code of Conduct bars councillors from being in arrears for more than three months.
05
Critical · unexplained cost

A R102.1m "loss on disposal of assets" is billed to customers

The pack says
General expenses include R102.1m of losses on disposal of assets, a non-cash item NERSA may query; excluding it would lower the required increase by about 3.4 points. F04 p6, p23
Why it matters
That is about R53 a month for a 400 kWh household, for assets that were sold, scrapped, stolen or written off. The pack doesn't say which. The MFMA (s14) restricts how municipalities may dispose of capital assets.
Demand
Publish the disposal register behind the R102.1m: each asset, its value, the reason, and the Council approval. Remove it from the revenue requirement.
06
Critical · losses

Electricity losses are rising, not falling

The pack says
Losses were 20.40% in 2023/24, 32.19% in 2024/25 and 32.31% in 2025/26. They were 37.72% in July–August 2026, and 40.05% in July 2026 alone. Non-technical losses (mainly theft and meter faults) cost R647.5m at cost price in 2025/26. F04 p25–28
Why it matters
The turnaround plan targets 32.22% for 2026/27 and 21.33% for 2027/28. Grant funding depends on reaching 28% by the end of 2026/27 (F01 p4). The current trend is moving the other way. BCMM's notice blames an 18% more Eskom bill. The losses report shows that 9.2% more energy was bought, while losses grew (F04 p26).
Demand
Publish monthly loss figures by substation area. Say what happens to the grant if the 28% target is missed. Name the official accountable for the loss targets.
Findings · High

Who carries the load, and how the system is run

07
High · cause not examined

Losses jumped in the same year the prepaid basic charge began

The record
2023/24: no basic charge on 1B, and losses of 20.4%. 2024/25: a basic charge of R376 began, billed sales fell by 121 GWh (−11.7%), and losses reached 32.2%. The pack puts the rise down to about 42,000 prepaid meters that stopped buying, and to tampering. F04 p28; BCMM tariff books 2023/24, 2024/25
Why it matters
Two things happening in the same year doesn't prove one caused the other. Still, a fixed charge billed whether or not you buy electricity gives struggling households a reason to stop buying from the City. The 121 GWh of lost sales is worth about R445m a year at today's average price. The pack never tests whether BCMM's own tariff design contributed.
Demand
Commission an independent analysis of the 42,000 non-purchasing meters: when each stopped buying, compared with when the basic charge started, and how many are faulty, vacant, or using another energy source.
08
High · hidden over-recovery

Prepaid homes are charged R118.7m more than it costs to supply them

The pack says
Scale 1B costs R890.4m to serve and would pay R1,009.1m, a ratio of 1.13. The design rule is that every category moves to its cost but by no less than Eskom's proposed increase of 8.01%. F04 p12–13
Why it matters
That works out to about R132 a month for each prepaid customer above their own cost of supply. The notice presents prepaid homes as being held to Eskom's increase (F01 p1). It doesn't tell them they are already paying more than they cost.
Demand
Price 1B at its cost of supply. Say plainly in the notice which customers pay above cost and by how much.
09
High · data integrity

The study is unfinished, keeps changing, and rests on data BCMM says is wrong

The pack says
The study's front page reads DRAFT FOR INTERNAL REVIEW. NOT FOR SUBMISSION. It went through eight versions between 15 and 20 October. The required increase moved from 16.9% to 15.6% to 12.5%, and the billing findings moved from about +R86m to +R12.2m. A R57.8m "finding" was withdrawn as a statistics error. Billing statistics understate sales by 47.6 GWh, and the forms sent to NERSA are being corrected. F04 p1–2, p19–20; F02 p2
Also
The covering letter calls the data audited 2025/26 (F04 p2). Under the MFMA (s126), the Auditor-General normally finishes the municipal audit by about the end of November, so the 2025/26 data could not have been audited when the study was written in October.
Demand
Don't submit to NERSA until the data is corrected and audited. Publish the corrected study and consult again on the final numbers.
10
High · billing failures

Thousands of accounts billed wrongly, in both directions

The pack says
Basic charges were never billed on 5,186 property units (R17.6m) and charged twice in 934 cases (R1.1m). Prepaid business (2B) was under-billed R22.1m because the vending tariff was loaded wrongly. Under-billing is to be back-billed. F04 p20, p23
Why it matters
Customers who were under-billed through no fault of their own now face back-bills. Customers who were overcharged get credits with no interest. Nothing says who loaded the wrong tariffs, or whether anyone benefited from the errors.
Demand
Limit back-billing to what the law allows and offer interest-free instalments. Pay interest on every over-recovery. Publish the root cause of each error and the controls that will stop it happening again.
11
High · missing money

R53.7m of the equitable share for free basic services isn't accounted for

The pack says
BCMM received R116.8m of electricity equitable share (national money for free basic services). Only R63.1m is credited to the social basket. F04 p1, p6, p12
Why it matters
The difference is R53.7m. The rest of the subsidy shortfall, R233.9m, falls on other customers (F04 p9). If more of the grant reached the social basket, other customers would carry less.
Demand
Show where the remaining R53.7m goes, and credit all of it against the social basket.
12
High · avoidable cost

BCMM pays Eskom for 76.6 MVA of capacity it doesn't use

The pack says
Eight Eskom supply points are booked for more capacity than they use (76.6 MVA not used), and five are booked for less. Fixing this would save R20.7m a year and needs only an application to Eskom. Status: application letter to Eskom drafted. 2025/26 also carried penalties for exceeding booked capacity (R0.5m) and interest on overdue Eskom accounts (R0.4m). F04 p6, p22–23
Why it matters
The saving needs only a letter, and the letter hasn't been sent. The notice says The City pays Eskom in full and on time every month (F01 p3), but 2025/26 includes interest on overdue Eskom accounts.
Demand
Send the application now and publish the date. Say how many years the over-booking has been paid for and what it cost in total.
13
High · enforcement

Revenue protection is too thinly staffed to dent theft

The pack says
The revenue protection section is at about 28% of its staff establishment (15 staff). It completed 278 domestic inspections in Q1 2026/27 and recovered R566,449 from domestic tampering. F04 p27
Why it matters
At that rate, inspecting each of the 146,794 meters once would take about 132 years. Domestic recoveries equal 0.29% of the non-technical losses for July–August alone (R195.0m). The cost of this gap lands on paying customers.
Demand
Fill the vacant posts before any increase takes effect, and report inspections and recoveries every quarter.
14
High · due process

A R7,000 penalty, payable upfront, by a group that includes faulty meters

The pack says
The smart-meter programme targets 54,000 meters, including prepaid meters that have stopped buying electricity and meters that do not work. An initial R7,000 punitive charge per affected customer is payable upfront before a smart meter is installed. The customer guide says R7,000. The charges annexure escalates it to R7,560.70. F01 p4; F03 p22, p27; F04 p26
Why it matters
A meter that stopped buying, or that is faulty, is not proof of tampering. Applied to all 54,000 targets, the penalty would raise up to R378m, mostly from struggling households. BCMM itself rates recovering punitive charges from customers who cannot afford them as a risk (F04 p27). By-law penalties can also be added on top: R9,569.69, a disconnection fee, a new meter and back-dated consumption.
Demand
Charge no penalty without documented evidence of tampering at that meter. Give customers a written notice and a right to appeal before any charge. Exempt faulty meters and indigent households. Publish the number of penalties charged and appealed.
15
High · priorities

More disconnections than new meters, through the festive season

The pack says
By 20 December 2026 the targets are 10,800 smart meters and 24,000 disconnections. The only progress figure published is 809 meters replaced or repaired, as at 22 October, against an October target of 3,000. The programme runs with Vodacom under a National Treasury contract. F01 p4; F02 p4; F04 p26
Why it matters
Disconnections outnumber installations more than two to one, during the comment period and over the holidays. The contract value, the cost per meter and the results of earlier smart-meter spending are not disclosed. Even with 45,796 smart meters already installed, losses rose.
Demand
Publish the RT29 contract value, the cost per meter and monthly progress against target. Publish an evaluation of the smart meters installed before 2026.
16
High · solar households

Solar homes face up to 30%, not the advertised 8%

The pack says
The headline for the 1,366 solar homes is 8.0%. Their basic charge rises from R514.30 to R821.17, which is +59.7%. The documents give three different figures for the same charge: R782.70, R825.11 and R821.17. Revenue is set 16% above cost to serve. Prepaid solar exports may be treated as meter interference. Credit above the monthly bill is forfeited. F03 p2, p14; F04 p14–15; F10 p3
Why it matters
A solar home that imports 100 kWh a month pays +30.1%; at 200 kWh it pays +18.3%. Households that invested in solar during load-shedding are priced above cost and pushed onto a higher fixed charge. Using the word "interference" opens the way to tampering penalties.
Demand
Phase in the solar basic charge and price it at cost. Publish one consistent figure. Remove the "interference" wording, and convert prepaid solar homes' meters without penalties.
Findings · Medium

Opaque deals, double payments and promises without teeth

17
Medium · transparency

Special tariffs with unnamed customers

The pack says
The business relief tariff is R3.00/kWh, held with no increase, for financially distressed businesses, old age homes. Customers: [to be confirmed from billing]. It does not appear anywhere in the cost-of-supply study. Two flat-rate tariffs each serve one customer, and one of them is frozen at 0%. The number of social housing customers is also [to be confirmed]. F03 p1–2, p10–11, p20; F04 p8–9
Why it matters
A rate below cost, given at Council's discretion to customers no one can see, is open to abuse.
Demand
Publish the criteria, the approving Council resolutions, the number of beneficiaries and the kWh for the relief tariff. Name the type of customer on each single-customer tariff.
18
Medium · paying twice

Street lighting +29% and the City's own buildings +21%, paid from rates

The pack says
Street and traffic lights rise 29.0% and internal municipal supplies 21.2%. Both were below cost (0.65 and 0.84). F04 p9, p13
Why it matters
When the City bills itself, ratepayers pay through property rates. These two categories add R44m a year and lift the "average" without bringing in new money. They also show that electricity customers had been subsidising the City's own power use.
Demand
Show the effect on the rates account. Publish the electricity bill of each municipal building and depot, with energy-saving targets.
19
Medium · misleading claim

"Losses above 12% are not charged to you" isn't the whole story

The pack says
The notice says the R638m is not charged to customers… the City carries it (F01 p3). The study says it is funded from the City's cash reserves, at the expense of network maintenance and makes the next tariff increase larger. F04 p7, p10
Demand
Correct the notice. Publish the maintenance backlog and how much maintenance was cut to cover the deficit.
20
Medium · question

Are customers paying depreciation on assets that grants paid for?

The pack says
Depreciation of R454.3m is included in costs. Capital grants and donated assets (R183.6m) and interest received (R76.7m) are not deducted. F04 p6, p8
Demand
Show how much of the depreciation relates to grant-funded or donated assets. Explain why interest received is not deducted.
21
Medium · incomplete

Key parts are missing or unconfirmed

The pack says
The loss-reduction plan (Annexure E) is [To be attached]. Whether BCMM met NERSA's 2025/26 directive is [To be confirmed: date submitted]. Disconnection, connection and deposit fees are [to be inserted]. By-law references are to be confirmed by BCMM Legal Services before publication. The wheeling rates differ slightly from the current cost of supply model. F03 p24–25; F04 p18–19, p24
Demand
Supply every missing item before the comment period closes, and extend the period if they come late.
22
Medium · accountability

"12.5% could be 4.2%", with nothing to make it happen

The pack says
If the recovery plans deliver, the required increase falls from the proposed 12.5% to about 4.2%. The largest step needs bad debt to fall 78% in a year, from R312m to R69.8m. F02 p4; F04 p22–23
Why it matters
Customers pay the full 12.5% now, while the savings stay hypothetical. Nothing passes the gains back to customers if they are achieved.
Demand
Commit to a mid-year tariff reduction or account credit if the recovery targets are met. Report progress against each target every quarter.
23
Medium · proportionality

Fines of up to R100 million for any breach of the by-law

The pack says
Any contravention of the by-law: a fine of up to R100 million, or imprisonment of up to 30 years, or both. F03 p23
Why it matters
Legal Services has not confirmed this, and it applies to minor breaches such as an unlocked meter room. Printing it in a customer guide is out of all proportion.
Demand
Publish a legal opinion on the penalty schedule and remove any penalty that cannot be justified.
24
Medium · wheeling

Wheeling charges designed so customers can't save money

The pack says
Wheeling rates include an 8.6% cross-subsidy mark-up, plus a further network contribution of 23.0c/kWh so that wheeling stays revenue-neutral. If NERSA refuses, BCMM reserves the right to withdraw the wheeling tariffs. F04 p17–18; F06 p4
Why it matters
Wheeling lets businesses buy cheaper power from other generators. These charges are designed to protect BCMM's margins rather than lower customers' costs.
Demand
Show that the 8.6% mark-up and the 23c contribution do not charge the same margin twice, and drop the threat to withdraw.
To be fair

What the pack gets right

Credit is due for these. The questions below are about everything else.

Act before 1 December 2026

What residents can do

1. Comment in writing

Use the submission builder. The notice has no comment email yet, so send your submission to the study's named contact, Chris Gower (Senior Revenue Protection Manager), at chrisg@buffalocity.gov.za, copy your ward councillor, and keep proof that you sent it.

2. Hand one in

Ask for the tariff comment form at any BCMM customer care centre. Get it date-stamped and keep a copy.

3. Go to NERSA too

NERSA runs its own 30-day public comment on BCMM's application in March–April 2027 (F02 p7). Send the same questions then.

4. Ask for records

Use the records request generator. Under the Promotion of Access to Information Act (PAIA), request the debtor analysis, the asset-disposal register, the RT29 contract and the relief-tariff beneficiaries.

Make your own submission in a few minutes

Choose the points you want to raise, add your name, account number and ward, and download your submission as Word or PDF, or open it in your email. Your ward councillor's contact details are filled in for you. Nothing you type leaves your device.

Make your submissionRequest records (PAIA / POPIA)
Sources and method

Where every figure comes from

We read all ten documents that BCMM published on 30 October 2026, from the "27/28 Draft Electricity Tariffs" folder at buffalocity.gov.za, along with BCMM's own tariff books for 2023/24 to 2026/27. Calculations use BCMM's published rates. File 05 of the pack is not published on the site. All 2027/28 figures are drafts and may change. The court case comes from news reports, and we could not confirm the outcome of the appeal.

  1. F01 · Have Your Say notice, draft electricity tariffs 2027/28
  2. F02 · Cost of supply study 2027/28: overview presentation
  3. F03 · Draft electricity tariff book 2027/28, with service, punitive and grid-study charges
  4. F04 · Cost of supply study report 2027/28, including the losses report (Draft 8)
  5. F06 · Electricity wheeling policy framework 2027/28
  6. F07 · Wheeling tariff calculations 2027/28
  7. F08 · Wheeling and service level agreement (template)
  8. F09 · Solar (SSEG) tariff options B and C: calculations
  9. F10 · Solar (SSEG) customer agreements A, B and C
  10. F11 · Tariff impact report, 2026/27 vs 2027/28
  11. BCMM tariff books: 2023/24 final · 2025/26 final · 2026/27 final
  12. Court case: Daily Dispatch, 7 Nov 2025 · Daily Dispatch, 12 Jan 2026 (appeal) · TimesLIVE, 12 Nov 2025 · DA Eastern Cape statement (partisan source)
  13. Background: Daily Maverick, NERSA approval process ruling, 2 Nov 2025 · TimesLIVE, service charge introduced, 5 Jul 2024