Submission on Starlink Licence Application – Namibia Consumer Protection Group

 Dear CRAN Licensing Department,

On behalf of the Namibia Consumer Protection Group (NCPG), I hereby submit our comments regarding the licence application of Starlink, as invited by the Communications Regulatory Authority of Namibia (CRAN).

Introduction

The Namibia Consumer Protection Group is committed to ensuring equitable access to essential services for all Namibians. Connectivity is no longer a luxury; it is a prerequisite for safety, education, and economic participation. Farmers and rural communities, in particular, face persistent challenges with unreliable or unaffordable internet services.

Context

Existing service providers have not adequately addressed the needs of rural consumers, leaving large parts of Namibia underserved. Farmers and agricultural organisations have expressed strong support for Starlink’s entry into the Namibian market, citing its potential to provide reliable connectivity where traditional infrastructure has failed.

Benefits of Starlink

We recognise the following consumer benefits:

• Rural Safety: Improved communication to address farm-related crime and enable digital surveillance systems.

• Modern Agriculture: Connectivity for precision farming technologies, automation, and access to online markets.

• Education and Services: Reliable internet for online education in remote areas and access to veterinary and advisory services.

• Consumer Choice: Starlink offers a direct response to years of unreliable or prohibitively expensive services from existing providers, thereby enhancing competition and consumer empowerment.

Ownership and Regulatory Considerations

While regulatory compliance is essential, ownership requirements must be balanced against the urgent need for rural connectivity. Namibia should consider alternative compliance mechanisms that ensure local participation without delaying service provision. These could include:

• Mandated investment in rural infrastructure and school connectivity.

• Partnerships with Namibian cooperatives, farmer unions, or community organisations.

• Transparent consumer protection frameworks to safeguard affordability and service quality.

Recommendations

We respectfully recommend that CRAN:

1. Grant Starlink a licence subject to clear consumer protection obligations, including affordability and transparency in pricing.

2. Prioritise rural coverage as a licensing condition, ensuring farmers and remote communities are the primary beneficiaries.

3. Encourage community participation in ownership or governance structures, without imposing barriers that delay service provision.

4. Safeguard consumer rights by requiring Starlink to comply with Namibian regulations on data protection, fair competition, and service reliability.

5. Monitor and evaluate impact through CRAN-led reporting mechanisms, ensuring measurable improvements in rural connectivity.

Conclusion

Connectivity is a fundamental consumer right. For Namibia’s farmers, it is a lifeline—supporting safety, modern agricultural practices, education, and access to markets. The Namibia Consumer Protection Group urges CRAN to approve Starlink’s licence application with conditions that protect consumers while enabling rapid deployment of services.

Respectfully submitted,  

Milton Louw  

Director  

Namibia Consumer Protection Group

081 688 1368

Starlink in Namibia: What Consumers Need to Know Before the Big Decision

Over the past few months, Namibia has seen renewed debate about whether Starlink — the satellite internet service developed by Elon Musk — should be allowed to operate legally in our country. As someone who has written extensively about consumer rights, digital equality, and regulatory fairness, I want to break down what this means for ordinary Namibians and why the discussion is more complicated than it looks.

Recent Developments: CRAN, Licensing, and Public Debate

Several important developments have shaped the current Starlink conversation:

• CRAN has ordered Starlink to stop all operations, claiming the company is operating without a required telecommunications licence.

• Equipment has been confiscated, and criminal cases opened against individuals using unlicensed Starlink terminals.

• Starlink has submitted a licence application, but approval is still pending.

• Concerns over ownership rules have emerged, with the Ministry of ICT reviewing whether Starlink meets local-ownership requirements for telecom operators.

• Public participation is coming: CRAN announced that Starlink’s licence application will be published for public review.

These events are not just regulatory formalities — they affect consumers directly.

Why Many Consumers Support Starlink’s Entry

1. Coverage for Rural and Remote Areas

Namibia’s size makes traditional broadband expansion slow and expensive. Starlink’s satellite-based system can reach clinics, farms, tourist lodges, and communities that fibre or towers may never reach.

Technology expert Paul Rowney recently highlighted that Starlink’s low-latency, high-speed service could drastically improve connectivity in rural Namibia.

2. Healthy Competition

Starlink doesn’t necessarily replace local ISPs like MTC or Telecom Namibia — instead, it introduces new competition that may push everyone to improve service quality and prices.

3. Development Boost

Connectivity is a multiplier:

• Remote learning improves

• Tourism operators benefit

• SMEs can operate more efficiently

• Farmers and health facilities can access real-time services

This aligns strongly with themes I’ve championed in previous blogs: digital access drives national progress.

4. No Infrastructure Burden on Government

Starlink uses its own satellite network, meaning Namibia doesn’t have to build new infrastructure to benefit. Rowney even suggested running a two-year trial to measure real impact with minimal risk.

But There Are Valid Concerns

1. Regulatory Fairness

Local ISPs must meet strict rules on taxes, employment, infrastructure and service obligations. Allowing Starlink to bypass these could create unfair competition.

2. Ownership Requirements

Namibian telecom law requires a level of local ownership or participation. Government reviews show Starlink’s proposed structure may not yet meet this requirement.

3. Consumer Legal Risks

Right now, using Starlink equipment is illegal under CRAN regulations. Consumers could face confiscations or cases until licensing is settled.

4. Pricing Sustainability

While early adopters are excited, long-term affordability is still uncertain. Terminal costs and monthly fees could lock out low-income users.

My Position as a Consumer and Citizen

Based on the facts, the best path forward is:

✔ Approve Starlink — with conditions

Regulatory approval should be transparent, fair and include consumer protections.

✔ Implement a trial rollout

A pilot in remote areas would show the real benefits before full national approval.

✔ Educate consumers

CRAN and the Ministry should run an awareness campaign so people understand the legal status and risks.

✔ Encourage partnerships

Local ISPs could partner with Starlink for rural expansion or back-up connectivity.

Why This Matters for Namibia’s Future

My earlier blog posts champion three themes: digital equity, consumer protection, and national development.

The Starlink debate touches all three.

• Digital equity: rural and low-income Namibians deserve reliable internet

• Consumer protection: rules must be clear and fair for everyone

• National development: Namibia’s growth depends on modern digital infrastructure

Approving Starlink responsibly could be a major step toward closing our digital divide.

Final Word

Starlink’s entry into Namibia has the potential to transform connectivity — but only if done right. As the public review process begins, consumers should speak up, ask questions, and demand transparency.

I’ll continue analysing developments as they unfold. For now, the most important thing is that Namibian consumers are informed, aware, and part of the decision-making process.

How Namibia Can Avoid the “Dutch Disease” Trap

Namibia is buzzing with talk of oil, gas, green hydrogen and new mining projects. Yes, the future looks promising. But before we get carried away, we must understand a dangerous economic trap called Dutch disease.

Don’t worry — it’s not a medical problem and it doesn’t involve tulips. It’s simply what happens when a country becomes excited about one big resource and, without realising it, weakens the rest of its economy.

Let me explain it in everyday language.

What is Dutch Disease? (The Milton version)

Imagine you’re selling tomatoes at the market. Then a new stall opens selling diamonds. Suddenly everyone is chasing diamonds.

What happens?

• Prices rise.

• Wages rise.

• The currency becomes stronger.

• Tomato farmers can’t compete.

• Soon, only diamonds matter.

Until the price of diamonds collapses — and then everyone suffers.

That’s Dutch disease.

Namibia is at risk if we don’t prepare properly.

Why Namibia Must Pay Attention

We’ve seen this story across Africa and beyond. A country discovers oil or minerals, gets a burst of cash, and then:

• Agriculture and manufacturing decline

• Small businesses struggle against cheap imports

• Government overspends

• Jobs don’t grow for ordinary people

• When the commodity price drops, the whole economy crashes

Namibia can avoid all this. But we must act early, not when the crisis arrives.

What Namibia Must Do to Protect Itself

1. Save before we spend

If you receive a bonus at work, you don’t use it all in one day. The country must do the same.

Namibia needs a proper, well-governed Sovereign Wealth Fund — not political window dressing, not a quick-cash machine.

It must have strict rules:

• Save most of the resource income

• Only a small, predictable amount goes into the annual budget

• Independent professionals oversee it

• Full public transparency

If we don’t save, we will overspend, push up prices, and weaken our own industries.

2. Keep the Namibia Dollar from becoming too strong

This part needs a clear explanation, especially because Namibia is part of the Common Monetary Area (CMA) with South Africa, Lesotho and Eswatini.

What does CMA membership mean?

• Our Namibia Dollar is pegged 1:1 to the South African Rand.

• We cannot independently let our currency weaken or strengthen.

• If foreign money pours into Namibia, we can’t simply adjust the exchange rate ourselves.

So what can we do?

How Namibia can still limit real appreciation under the CMA

Even with the fixed peg, we have tools:

• Build foreign reserves through the Bank of Namibia.

• Channel resource revenue abroad via the Sovereign Wealth Fund.

• Avoid excessive government spending, which pushes up local prices and wages.

• Coordinate closely with the South African Reserve Bank on liquidity and capital flows.

In simple terms:

We cannot change the exchange rate — but we can control the pressure that makes prices rise too fast.

If we don’t manage this, agriculture, manufacturing and exporters will struggle, because their products become too expensive compared to imports from South Africa and the rest of the world.

3. Protect and grow the sectors that employ people

Oil and gas do not create enough jobs. If we rely on them alone, unemployment will stay high.

We must strengthen the industries that can employ thousands:

• Farming and agro-processing

• Tourism

• Fisheries and value-addition

• Light manufacturing

• SME services and suppliers linked to big projects

Resource money should help these sectors grow — not destroy them through high local costs.

4. Invest in people, not only in big projects

Infrastructure is important, but skills are even more important.

Use resource income to:

• Improve vocational and technical training

• Support apprenticeships and youth programmes

• Build entrepreneurship pathways

• Train welders, engineers, digital creators, technicians

• Strengthen community colleges and TVET centres

If Namibians lack skills, foreign workers will take the well-paid jobs — and we’ll watch our own wealth pass us by.

5. Fight corruption before it eats the future

Let’s be honest: corruption destroys resource wealth faster than anything else.

We need:

• Transparent contracts

• Public reporting of every payment

• Real procurement oversight

• Strong parliamentary scrutiny

• Independent audits that are published

If we fail here, everything else collapses.

6. Spend wisely — not wildly

Resource income must never be used to inflate the government wage bill or make permanent promises we cannot afford.

Spend on things that last:

• Roads and rail

• Schools and teachers

• Hospitals and clinics

• Water systems and desalination

• Electricity and ports

These are investments, not expenses.

A Simple Action Plan

0–12 months

• Pass a firm, transparent Sovereign Wealth Fund law.

• Publish the rules: what goes in, what comes out.

• Tighten financial controls to reduce waste.

1–3 years

• Build foreign reserves and invest resource flows abroad to ease pressure on the Namibia Dollar.

• Strengthen TVET training and SME support.

• Launch value-addition pilots in mining, agriculture and fisheries.

3–10 years

• Stay disciplined with savings.

• Grow export-ready industries.

• Maintain strict transparency and public reporting.

• Prepare for the day when oil or mineral revenue declines.

  
  

Final Word

Dutch disease is not a fate — it’s a warning.

Namibia has time to choose a better path.

We can be like Norway — steady, wealthy and prepared —

or like nations that got rich fast and poor twice as fast.

If we stay disciplined, transparent and strategic, our natural resources can lift every Namibian, not just a lucky few.

This is our chance. Let’s not waste it.

Why Debt Counselling Must Return to Namibia’s Consumer Credit Bill

Namibia’s new Consumer Credit Bill is a step forward—but not without a stumble.

As someone who’s spent years tracing the impact of credit agreements on ordinary Namibians—from pensioners to young families—I must raise the alarm. The latest draft of the Bill, submitted to the Minister of Finance in October 2025, quietly removed Section 110. That section dealt with debt counselling and prescribed debt. Its absence is not just a technical tweak—it’s a blow to consumer dignity.

What Was Removed—and Why It Matters

Section 110 gave NAMFISA the power to regulate debt counselling services. That meant trained professionals could help over-indebted consumers restructure their debts, avoid court action, and regain financial stability.

Without it:

- There’s no formal pathway for consumers to seek help before legal enforcement begins.

- NAMFISA cannot license or regulate debt counsellors.

- Vulnerable Namibians are left to fend for themselves in a system stacked against them.

Debt Counselling Is Not a Handout—It’s a Lifeline

Namibians are proud and resilient. But resilience should not be mistaken for silence. When a mother in Katutura juggles five microloans to keep food on the table, or a pensioner in Oshakati faces repossession over a misunderstood credit facility, we must ask: where is the system that helps them recover?

Debt counselling is about dignity. It’s about giving people the tools to understand their obligations, negotiate fairly, and avoid the spiral of default and shame.

South Africa recognised this years ago. Their National Credit Act includes debt counselling as a statutory remedy. Why should Namibians be denied the same?

A Simple Fix

We’re not asking for bureaucracy. Just one clause that gives NAMFISA the legal authority to regulate debt counselling. Something like:

“The Consumer Credit Regulators may, in accordance with prescribed standards, establish or accredit debt counselling services to assist consumers who are over-indebted or at risk of default.”

This would allow for a national framework—without waiting for another legislative cycle.

Our Call to Action

As Executive Director of the Namibia Consumer Protection Group, I urge Parliament, the Ministry of Finance, and NAMFISA to reinstate debt counselling in the final version of the Bill.

Let’s not build a credit system that punishes hardship. Let’s build one that rehabilitates, educates, and protects.

Because credit should be a bridge—not a trap.

Have thoughts on this? Drop a comment below or share this post with someone who cares about consumer rights. Let’s make our voices heard.

Broadband in Namibia: A Historical Perspective and the Path to Inclusive Connectivity

Internet connectivity has become as vital to daily life as electricity and water. From accessing education and healthcare to running businesses and staying connected, broadband internet’s role in development is undeniable. Yet in Namibia, like many countries in the Global South, this lifeline has not been universally accessible or affordable since its early days.

Reflecting on Namibia’s broadband story reveals a journey marked by steady progress but also persistent challenges. Understanding where we have been helps us chart how to take broadband to every corner of our nation, ensuring no one is left behind in the digital revolution.

Early Days: Laying the Foundations

Namibia embarked on its telecommunications journey in the early 1990s—shortly after gaining independence—with rudimentary, dial-up internet that served only a few urban centers. Internet infrastructure was sparse and slow, the cost was prohibitive, and the reach beyond Windhoek and a handful of towns was almost nonexistent.

This era was shaped by government and parastatal efforts to modernize Namibia’s telecoms. Key achievements included automating exchanges in towns and introducing digital lines, fiber optic cables, and packet-switched networks. These upgrades began the slow move from analog to digital, from limited phone lines to the promise of genuine internet access.

Notably, the government recognized broadband's transformative potential early on and later adopted a National Broadband Policy to provide strategic direction. This policy aims to weave broadband into the fabric of economic growth, education, and digital inclusion.

The Contemporary Landscape: Progress with Uneven Reach

Today, Namibia has witnessed significant improvements. Telecom Namibia and private players have rolled out fiber optic cables linking major towns and expanding to suburban areas. Mobile broadband networks such as 4G cover a vast majority of the population, and initial 5G deployments signal future potential.

Despite these advances, broadband quality and coverage remain uneven. Urban and peri-urban areas enjoy relatively stable connections, but many rural and remote communities still suffer poor or no access. Namibia’s average broadband speed hovers at around 13 Mbps, a speed far below more developed nations and even some regional neighbors.

Affordability is another serious barrier. High costs for data and internet-enabled devices exclude many Namibians from meaningful online participation. The high cost of doing business online further slows economic diversification and innovation.

According to recent data, approximately 53% of Namibians have internet access, while mobile network coverage is broad but many subscriptions are prepaid and limited by data affordability. In many households, devices remain scarce or shared, limiting connectivity’s full educational and social benefits.

The Digital Divide: Challenges and Consequences

Namibia’s rapid progress masks an underlying digital divide. This divide is about much more than bits and speeds; it reflects unequal opportunity, widening social disparities, and regional imbalances.

Children in well-connected urban homes can access digital classrooms and online resources, while rural youth may rely on limited public computer centers or none at all. Entrepreneurs in cities can reach global markets; rural farmers struggle to find weather updates or market price information online.

Cost barriers mean many Namibians cannot participate in the digital economy or utilize online government services. Women, persons with disabilities, and marginalized groups often face even greater hurdles.

The digital divide undermines national goals for inclusive growth and social cohesion. Without targeted action, broadband could deepen inequality rather than close it.

What Must Be Done: A Call for Equitable Connectivity

To build a Namibia where everyone can benefit from broadband, concerted efforts are needed across multiple fronts:

• Accelerate Infrastructure Expansion: The government and private sector must increase investments to extend fiber networks and mobile broadband deep into rural and underserved areas. Technologies such as fixed wireless access and satellite internet can complement fiber in hard-to-reach locales.

• Make Connectivity Affordable: Reducing costs for broadband data and devices is vital. This can be achieved through subsidized tariffs, tax incentives for internet-capable devices, and public-private partnerships to share infrastructure costs and broaden market competition.

• Boost Digital Literacy: Connectivity without the skills to use it effectively is limited. Comprehensive digital skills training, especially aimed at vulnerable groups and rural users, will ensure broadband translates into real opportunity.

• Expand Public Access Points: Community internet hubs, telecenters, and libraries should be supported to provide free or low-cost internet access for those who cannot afford home connections.

• Inclusive Policy and Regulation: The government must maintain a policy environment that encourages fair competition, protects user rights, and promotes universal service obligations among operators.

• Collaboration for Innovation: Partnerships between government, civil society, and the private sector can foster innovative solutions tailored to Namibia’s unique geography and social context.

Looking Ahead

Namibia’s broadband story is one of transformation from scarce dial-up connectivity to the cusp of widespread fiber and mobile 5G. Yet, the promise of an inclusive digital future remains unfulfilled unless the digital divide is addressed head-on.

Broadband is not a luxury — it is a necessity for social and economic inclusion. Ensuring affordable, quality access to reliable internet and devices nationwide will empower Namibians to pursue education, create businesses, access health services, and participate fully in civic life.

With thoughtful policies, sustained investment, and community-focused action, Namibia can move beyond digital disparities. The road ahead is clear: broadband must become a shared resource for all Namibians, closing gaps and opening doors to opportunity in every corner of the country.

Old Debts, New Tricks: What Every Namibian Should Know About Prescription, Debt Collections & Your Rights

Debt collectors are still sending SMSs and letters demanding payments for accounts from years ago, often threatening blacklisting or service cut-offs. Many consumers panic and pay small amounts just to “make a plan.” But in Namibia, not all debts can be enforced forever — and making a payment can revive a prescribed (i.e. expired) debt.

Here’s how the law works (as of 2025), what has changed, and how you can defend yourself.

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1. The Legal Basis: Prescription of Debt in Namibia

The Prescription Act 68 of 1969

• In Namibia, the Prescription Act 68 of 1969 governs how debts become “extinct” (i.e. unenforceable) after a certain period.  

• Section 10 of the Act provides that debts are extinguished by prescription if not claimed within the prescribed time.  

• The usual three-year period applies for most debts arising from a contract or a typical consumer obligation.  

• Some other kinds of debts (e.g. secured debts or judgments) may carry longer prescription periods (e.g. 30 years) under certain circumstances.  

When Prescription Starts & What Can Interrupt It

• Prescription begins to run from the date the debt becomes due (or from the last date when the debtor was aware).  

• If the debtor acknowledges liability (e.g. by paying, or promising to pay), or if a judicial process (like a summons) is served, prescription is interrupted, and the period starts afresh.  

• However, merely sending a demand letter or SMS (without court authority) is not always sufficient to interrupt prescription. The process must satisfy legal requirements.  

• Courts in Namibia have entertained “special plea of prescription” motions — i.e. defendants ask that a court dismiss the claim on the basis that the debt has prescribed.  

Judicial Precedents

• The High Court in Windhoek has in multiple cases upheld that a plaintiff’s claim was prescribed under section 11(d) of the Prescription Act.  

• Also, courts have warned that a creditor must properly serve process to interrupt prescription, and failure to do so can cause lapse of the cause of action.  

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2. The Current Legal Environment & Gaps

Weak Regulation of Debt Collectors

• Namibia currently lacks a comprehensive regulatory framework specifically for debt collection or “debt-management firms.” Many consumers fall prey to unregistered or unscrupulous firms.  

• However, a recent draft Consumer Credit Bill under NAMFISA (the financial regulatory body) is expected to incorporate regulation of debt collectors.  

Consumer Protection in Policy, but Not Yet Full Law

• Namibia has adopted a National Consumer Protection Policy (2020), which aims to guide the development of consumer protection laws and regulate unfair consumer practices.  

• But as of now, there is no single strong Consumer Protection Act that specifically limits abusive collection behavior, unlike in some other jurisdictions.

• This means many protections depend on general legal principles (e.g. contract law, common law, constitutional rights) and on raising defences like prescription in court.

Credit Bureaus & Data Sharing

• Under existing statutes, credit bureaus are regulated, and rules exist regarding what information they may collect or share.  

• Importantly, a person may not be registered as a credit bureau if they also operate as a credit provider or debt collection agency — a measure to avoid conflict of interest.  

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3. What Happens When a Debt Collector Contacts You

When you receive any demand — SMS, phone call, letter — here is what to do, step by step:

Step A: Demand Proof

• Ask them to prove the debt:

   • What is the original creditor?

   • What is the date of the debt (when it became due)?

   • Attach statements showing last payment or lack thereof.

• If they cannot show you solid proof, you can refuse to engage further.

Step B: Check Prescription

• Examine whether three years or more have passed since the debt became due, and since any last payment or acknowledgement.

• If the debt is older than three years, and there is no valid interruption, the debt is likely prescribed and cannot be legally enforced.

Step C: Lodge a Registered Letter / Special Plea

• You should send a registered (or certified) letter to the creditor or collection agency, stating that you consider the debt prescribed under the Prescription Act, and formally refusing further payments.

• If they go to court, you (through your lawyer or in person if allowed) should raise a “special plea of prescription”— a legal defence asking the court to dismiss their claim because it is time-barred.

• You bear the burden of showing the timeline (dates of last payment, acknowledgment, etc.).

Step D: Do not make any payments

• Never pay even N$1 if you believe the debt is prescribed — any partial payment can restart or revive the debt.

• Do not agree to “payment plans” or “minimum payments” until you have confirmed the validity and non-prescription of the claim.

Step E: Monitor Legal Proceedings

• If a summons or court documents arrive, do not ignore them — respond in court, stating your defence of prescription.

• In your court filings, include detailed timeline evidence to show the debt is time-barred.

Step F: Report Misconduct (if applicable)

• If a debt collector is using threats, intimidation, or false claims (e.g. “we will blacklist you tomorrow”), document this (screenshots, recordings, dates).

• You may file a complaint either with Namfisa (once debt collectors fall under its purview) or the Ministry of Industrialisation & Trade / consumer protection office, referencing unfair practices.

Telemarketing in Namibia: When “No” Should Mean “No”

“Our privacy and freedom of choice should matter too!” a frustrated consumer recently wrote to me. “Why are these companies allowed to flood our phones with adverts we never asked for?”

That question hits right at the heart of a growing problem in Namibia — unsolicited marketing messages that arrive without our consent and without any easy way to say stop.

Let’s be clear: under the Electronic Transactions Act of 2019, companies are already supposed to include an opt-out in every promotional SMS or email. They must also disclose who they are and where they got your details. In other words, consent matters — at least on paper.

The trouble is that enforcement is weak. Many consumers don’t even know these rights exist, and the law focuses mainly on electronic messages like SMS and emails, not voice calls. So when that “exclusive offer” call interrupts your lunch, it’s not entirely clear if anyone has broken the law.

The long-awaited Data Protection Bill — which government says will soon go before Parliament — promises stronger safeguards. It could finally spell out our right to say no to unwanted marketing, hold companies accountable, and ensure Namibians have true control over their personal information.

Until then, we remain caught in a grey zone where companies can market first and ask for forgiveness later. It shouldn’t be this way. Consumers deserve the simple right to choose whether to receive marketing messages — not to be bombarded without consent.

Privacy isn’t a luxury. It’s a right. And it’s time our laws — and regulators — treated it that way.

Proposal for a National Pension Tracing Service in Namibia: A Private-Public Partnership Model

1. Executive Summary

This proposal outlines the establishment of a National Pension Tracing Service (NPTS) in Namibia, structured as a Private-Public Partnership (PPP). The NPTS aims to address the significant issue of lost pension accounts and unclaimed benefits, ensuring that Namibian citizens can easily locate and claim their rightful retirement savings. By leveraging the strengths of both the public and private sectors, the NPTS will enhance consumer protection, improve efficiency in the pension system, and foster greater trust among the populace.

2. Background and Rationale

The analysis of Namibia's pension landscape, juxtaposed with international experiences, highlights a pressing need for a centralised mechanism to reconnect individuals with their lost pension entitlements. The current system, which often places the onus on individuals to trace their benefits, has resulted in a substantial volume of unclaimed funds, affecting a considerable percentage of the population. A dedicated national tracing service, particularly one that combines governmental oversight with private sector agility and expertise, is crucial to rectify this situation.

3. Objectives of the National Pension Tracing Service (NPTS)

• Simplify Tracing: Provide a single, user-friendly point of contact for individuals to inquire about and trace all their pension entitlements across various pension funds and employers in Namibia.

• Reduce Unclaimed Benefits: Proactively identify and facilitate the reunification of lost pension accounts and unclaimed benefits with their rightful owners or beneficiaries.

• Enhance Transparency: Improve data collection and reporting on lost accounts and unclaimed benefits, offering greater transparency to regulators and the public.

• Increase Consumer Confidence: Build trust in the Namibian pension system by demonstrating a commitment to protecting members' interests and ensuring access to their savings.

• Improve Efficiency: Streamline the process for pension funds to manage and resolve lost accounts, reducing administrative burdens.

4. Private-Public Partnership (PPP) Model

This model proposes a collaborative framework where the Namibian government, through NAMFISA, provides the regulatory and oversight framework, while a private entity (or consortium) brings technological expertise, operational efficiency, and tracing capabilities.

4.1. Roles and Responsibilities

Public Sector (NAMFISA and relevant Government Ministries):

• Regulatory Oversight: Establish the legal and regulatory framework for the NPTS, including data submission requirements for all pension funds.

• Policy Direction: Define the strategic objectives, operational standards, and performance metrics for the NPTS.

• Data Governance: Ensure robust data protection, privacy, and security protocols are in place, in line with national and international best practices.

• Public Awareness Campaigns: Lead national campaigns to educate citizens about the NPTS and the importance of pension management.

• Dispute Resolution: Provide an independent mechanism for resolving complex disputes related to pension claims.

• Initial Funding/Seed Capital: Provide initial funding or guarantees to kickstart the establishment of the NPTS.

Private Sector Partner(s):

• Technology Development & Maintenance: Design, develop, and maintain the IT infrastructure for the NPTS, including a secure database and user-friendly online portal.

• Operational Management: Manage the day-to-day operations of the tracing service, including handling inquiries, processing tracing requests, and liaising with pension funds.

• Tracing Expertise: Employ advanced tracing methodologies and tools (e.g., data analytics, skip tracing) to locate missing individuals and beneficiaries.

• Customer Service: Provide professional and accessible customer support to individuals seeking to trace their pensions.

• Innovation: Introduce innovative solutions and best practices from international experience to continuously improve the service.

• Co-funding/Investment: Contribute financially to the establishment and ongoing operation of the NPTS, potentially through a revenue-sharing model or performance-based incentives.

4.2. Partnership Structure Options

Several PPP structures could be considered, depending on the desired risk allocation and investment:

• Build-Operate-Transfer (BOT): The private partner builds and operates the NPTS for a specified period, then transfers it to the government.

• Management Contract: The private partner manages the NPTS operations for a fee, with the government retaining ownership of assets and strategic control.

• Joint Venture: A new entity is formed, jointly owned and operated by public and private partners, sharing risks and rewards.

5. Benefits of the PPP Model

• Efficiency and Speed: Private sector expertise can accelerate the development and deployment of the service, bringing best-in-class technology and operational practices.

• Cost-Effectiveness: PPPs can often achieve better value for money by transferring risks to the private sector and leveraging private investment.

• Innovation: Private partners are incentivised to innovate and improve service delivery to meet performance targets.

• Specialised Skills: Access to specialised tracing and IT skills that may not be readily available within the public sector.

• Enhanced Public Trust: A well-run, efficient service, backed by both government authority and private sector professionalism, can significantly boost public confidence in the pension system.

6. Key Considerations for Implementation

• Legal and Regulatory Framework: Enacting specific legislation or regulations to enable the NPTS and define the obligations of pension funds to submit data and cooperate.

• Data Security and Privacy: Implementing stringent data protection measures and ensuring compliance with all relevant privacy laws (e.g., GDPR principles, if applicable, or a robust Namibian equivalent).

• Funding Model: Determining a sustainable funding mechanism, which could include a levy on pension funds, government allocation, or a fee-for-service model (for successful tracing, paid by the fund).

• Stakeholder Engagement: Comprehensive engagement with all stakeholders, including pension funds, trade unions, employer associations, and consumer advocacy groups, to ensure buy-in and successful implementation.

• Technology Infrastructure: Ensuring compatibility and secure data exchange between the NPTS and existing pension fund systems.

• Performance Metrics: Establishing clear, measurable key performance indicators (KPIs) for the NPTS to track its effectiveness in tracing and reuniting benefits.

7. Conclusion

The establishment of a National Pension Tracing Service through a Private-Public Partnership represents a forward-thinking solution to a persistent challenge in Namibia's pension system. By combining the regulatory power of the state with the innovation and efficiency of the private sector, Namibia can create a robust, reliable, and consumer-centric service that ensures citizens receive their rightful retirement savings, contributing to greater financial security and public welfare. This proposal serves as a foundational document for further detailed investigation and feasibility studies.