Article 6 – Is a Signed Letter Enough?

The six practical modules may be one of the strongest parts of the new pathway – if we can prove they actually happened.

The alternative competency route is often described simply as:

Matric + examination + six practical modules.

Those last four words deserve much more attention.

The six modules are not supposed to be decorative.

PPRA’s practical-training guidelines cover workplace competence including regulatory compliance, ethics, client relationships, market development, management of the real-estate function and financial business principles. (Scribd)

In principle, this is exactly what critics of the reform should want.

Someone should not simply memorise an examination.

They should demonstrate competence in the workplace.

But then we encounter a control question.

Under the existing practical-training procedure, the Candidate submits a letter confirming completion of the six modules, co-signed by the mentor. PPRA then issues its approval after receiving confirmation of completion. (Scribd)

That may be perfectly adequate as a regulatory submission.

But should it be adequate as the agency’s evidence of competence development?

I don’t think those are the same question.

A letter tells us:

“The mentor says the Candidate completed the modules.”

An evidence trail could tell us:

what was done;
when it was done;
who supervised it;
which real workplace activity demonstrated the competence;
where problems were identified;
what corrective coaching occurred;

and

whether the Candidate eventually demonstrated the required standard.

That does not mean PPRA should receive hundreds of pages of documents from every Candidate.

More paperwork does not automatically create better regulation.

In fact, returning to enormous logbooks simply for the sake of having enormous logbooks would risk recreating exactly the red tape the reform is attempting to remove.

There is another way.

The agency retains the evidence.
The regulator receives a structured attestation.
PPRA can then request or audit the underlying evidence where necessary.
This is similar to how many mature control environments work.
The regulated entity owns the operational evidence.
The regulator sets the standard and retains oversight.

The problem occurs when the underlying evidence does not exist at all.

This is particularly important because the industry is now being asked to trust competency rather than relying exclusively on formal qualification.

If competency is the new currency, evidence becomes incredibly important.

Which takes us back to the consumer-protection concern.

Removing unnecessary educational barriers should not result in:
“Trust us, this person is ready.”
It should result in:
“Here is the evidence showing why we believe this person is ready.”
That is a much stronger proposition.

So I would like PPRA to clarify whether the 2026 pathway will introduce a prescribed minimum workplace evidence standard supporting the six-module sign-off.

Not necessarily a giant portfolio.

But a defensible evidence framework.

If we are going to replace some formal qualification requirements with demonstrated competency, shouldn’t demonstrated competency be demonstrable?

That may be one of the most important safeguards in the entire reform.