This briefing note draws from a paper on the coal value chain for the Sector Jobs Resilience Plans published by Trade and Industrial Policy Strategies.
South Africa’s transition to a lower carbon economy is likely to impact production technology choices, workers, households and mining-dependent municipalities. Social and Labour Plans (SLPs) are an existing regulatory mechanism that could help anticipate and manage these impacts. While the plans do not meet all the requirements for a just transition, they can support mine-linked worker development, community resilience and advance planning for downscaling. Further, SLPs can connect these measures to broader support systems for diversification, labour-market support and social protection.
Under the Mineral and Petroleum Resources Development Act No. 28 of 2002, an approved SLP is a requirement for obtaining mining rights. The original aim was to ensure mine owners prepare for the ultimate exhaustion of the ores and the consequent mine closure. The SLP must provide for human resource development; local economic development (aligned with Integrated Development Plans); management of downscaling and retrenchment; and financing for these commitments. Regulatory amendments introduced in 2020 strengthened requirements for meaningful consultation through publication, regular community meetings and five-year reviews.
These obligations align well with the requirements of the just transition. Human resource development can support reskilling, portable skills and redeployment. Future Forums and retrenchment planning can provide early warning and activate employment and income-support responses. Local economic development projects can contribute to regional diversification. Consultation, reporting and review can strengthen transparency, coordination and accountability.
In practice, the evidence indicates that SLP implementation is fragmented and largely compliance-driven. Often the programmes resemble corporate social investment programmes more than an integrated plan to manage the socio-economic risks of mining dependency. Community projects tend to be small, short-cycle and weakly connected to durable livelihoods. SLP reporting tends to concentrate on activities completed, rather than specific outcomes such as sustained employment, income or enterprise survival. Stakeholders often struggle to reconcile reported delivery with original commitments, budgets and beneficiaries. Consultation remains uneven, enforcement is inconsistent, and contractor, outsourced and non-unionised workers may be excluded from visible planning. To date, SLPs have been poorly integrated with Sector Jobs Resilience Plans (SJRPs) and wider Just Energy Transition structures.
The role of SLPs differs between the coal and metals, although both value chains face proximal decarbonisation impacts.
In coal, the transition risk is concentrated geographically and subject to clearer time pressures. Coal mining employed about 100 000 workers in 2024, with approximately 86% located in Mpumalanga. Here, SLPs can support near-term workforce profiling, readiness planning and coordination of commitments in priority coal municipalities. That said, most transition decisions are controlled by downstream actors such as Eskom and Sasol, which are not required to develop SLPs.
In metals the most immediate transition risks also arise in energy-intensive downstream smelting and refining, rather than the mines themselves. As a result, SLPs have a smaller role to play. Mostly they can support efforts to strengthen the resilience of mining-dependent areas and monitor longer-term risks to mining. This is especially important in areas with limited alternatives, including Bojanala, Waterberg and Sekhukhune.
To strengthen their contribution to a just transition in mining, the SLPs could be reformed in four ways.
- A dedicated structure should maintain a consolidated register of SLP commitments, expenditure, beneficiaries, milestones and delivery status, with escalation channels into mineral-regulation compliance processes.
- Local economic development commitments should feed into coordinated municipal and regional diversification pipelines rather than operate as isolated SLP projects.
- Workforce data and Future Forums should trigger early profiling, counselling, training, job matching and social-protection referrals before retrenchments occur.
- Supplementary employer data should cover contractors and outsourced workers.
Ultimately, monitoring should shift from counting outputs to assessing whether interventions produce durable jobs, incomes and community resilience.
Muhammed Patel is an economist at Trade and Industrial Policy Strategies.
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