In May 2025, the Socio-Economic Rights Institute of South Africa (SERI) submitted comments to the City of Johannesburg on its draft informal settlement policy published in February 2025. SERI welcomes the development of a policy on informal settlements by the City and views it as an important and much-needed step towards addressing the needs of residents in informal settlements. However, SERI submits that in its current form, the draft policy requires substantial revision to ensure that it is legally sound, inclusive, and responsive to the realities of informal settlements.
SERI's submission highlights concerns regarding the policy’s opaque public participation process, problematic terminology (such as "land invasion" and "recognised informal settlements"), and the lack of intersectional analysis to address the needs of vulnerable groups. We also provide recommendations to strengthen the policy’s grounding in law, its responsiveness to the lived realities of informal settlements, and its implementation through equitable funding and institutional coordination. In the submission, SERI urges the City to revise the draft policy to ensure that it aligns with constitutional and human rights standards, promotes inclusive development, and meaningfully engages communities in shaping their futures.
The recommendations in the submission range from the removal of stigmatising language such as "land invasion" to the incorporation of intersectional analysis and meaningful public participation. Furthermore, the policy must be strengthened by clear, legally precise definitions, a commitment to in situ upgrading in line with the UISP, and robust mechanisms for intergovernmental coordination and funding. The City's proposed Informal Settlements Management Unit holds promise but must be adequately resourced and structured to avoid past pitfalls, such as over-reliance on consultants and fragmented implementation.
SERI submits that the success of this policy hinges on its ability to move beyond containment and control toward a transformative vision of urban inclusion that recognises informal settlements not as disruptions to be managed, but as communities deserving of dignity, security, and development. SERI urges the City to revise the draft policy accordingly and welcomes all opportunities to support efforts that align with these principles.
- Download the submission here.