Dear Commissioner Mkhwanazi-Xaluva and Professor Xulu,
We congratulate the CRL for initiating critical reforms in faith sector accountability. As collective structures with many partners, We Will Speak Out South Africa and the Faith Action Collective to End Gender-Based Violence, work to equip the religious sector to address gender-based violence and femicide (GBVF) effectively. We are closely guided by survivors of church abuse, and so we understand the deeply entrenched nature of the abuse of power in religious institutions. We acknowledge your courage in pursuing “a system that enables religious leaders to hold one another accountable, promoting a culture of transparency, responsibility and empathy.”
We support prioritising the Christian sector and endorse a Section 22 Committee comprising faith representatives rather than direct government regulation, which risks curbing religious freedom and undermining the church’s prophetic role. The Committee’s mandate— facilitating consultative dialogues, registering faith practitioners, drafting a Charter and Code of Ethics, and proposing self-regulation mechanisms to Parliament—is vital.
However, having engaged with the CRL and the parliamentary processes for some time, ever hopeful of a new era in church accountability, we must express serious reservations about implementation, which threatens to undermine this important initiative.
Representation and Process Issues Undermine Legitimacy and Credibility
We concur with recent media statements published on October 14th: the all-male Committee composition is profoundly insulting to women in the church, theologically unsound, and practically undermines the Committee’s founding principles. 1
We appreciate your recognition that this is a genuine concern and your commitment to ensure that gender representation has been addressed. But that is not enough.
We call for a public announcement detailing the measures undertaken related to revised composition, criteria for selection, and assurance of at least a 50/50 gender balance. True representation of South African church membership would include at least 70% women, given their proportion in most Christian churches.
However, gender balance alone is insufficient. Many women have been socialised into patriarchal norms. A balanced committee must include critical voices— theologians, activists, and crucially, survivors, disability advocates and young people—who can genuinely guide inclusive and courageous consultation processes.
The selection process itself is deeply flawed in other ways, too. First, requesting nominations solely from senior leadership of selected worship institutions perpetuates the same male- and clergy-dominated power structures that have enabled abuse and have increasingly driven mass exodus among women, youth, and LGBTIQ+ communities whose stories have been silenced.
Second, the uneven representation of umbrella structures needs review. The Committee’s credibility suffers from giving seats to individual traditions like Rhema Church and Shembe splinters while limiting other umbrellas to single representation, like the SA Council of Churches—representing 36 denominations and 16-18 million Christians.
Third, why exclude umbrella structures focused on religious engagement with social justice issues? Organisations like the Circle of Concerned African Women Theologians, We Will Speak Out South Africa, the Faith Action Collective and others bring years of expertise on religious transgressions, safeguarding and creating safe, inclusive worship and ministry spaces offering Christ-modelled healing ministries.
The lack of transparent selection criteria has compounded the often-virulent conservative backlash that has bedevilled your efforts for years, and has even created reservations among those who support the concept in principle. Democratic norms require publicly calling for nominations with clear TORs and nomination criteria as well as ensuring balance across gender, age, disability, and diverse theological persuasions.
Sadly, this flawed process exemplifies the kinds of hierarchical and patriarchal practices that the CRL is actually mandated to address—potential abuse of clerical power that silences the majority and entrenches injustice and vulnerability.
Recommendations for Moving Forward
To ensure the Committee’s work withstands scrutiny and that its recommendations are workable, we propose:
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- Revisiting the Selection Process using transparent, democratic methods with publicly stated criteria.
- Augmenting Expertise: Assigning complex, sector-changing tasks to senior religious leaders without technical support sets them up for failure. The Committee composition needs to incorporate Christian professionals with expertise in:
- Facilitating safe, courageous consultative processes that centre marginalised voices.
- Research methods to gather the data and objectively analyse the vast number of diverse and nuanced submissions that will be gathered through the consultations,
- Gender-based violence and the diverse forms of abuse of power in the church sector, including spiritual abuse,
- Legal and constitutional aspects of possible accountability mechanisms,
- A scholarly theological understanding of the diverse theological frameworks across the broader church.
- Strategic Communication: A professional communications strategy (that includes constant public updates and reports, and ensures that consultative meetings are timeously advertised and recorded) is essential to ensuring acceptability, accessibility and ownership by all stakeholders of the process and the ultimate accountability mechanism proposed to Parliament.
Conclusion
We reaffirm our full support for the CRL and the Section 22 Committee’s work toward religious sector self-regulation. We cannot allow this vital contribution to rebuilding public trust in the faith sector to be undermined by flawed and unjust execution.
We do not just come with critique but also express a willingness to assist the Committee to undertake the corrective measures needed to succeed in its mission. In the same spirit, we hope to receive a timely and open-minded response in the next fortnight at least. To succeed, the composition of the Committee and consultation, research and the resultant proposals must mirror the transparency, diversity, and commitment to justice this initiative intends to achieve.
It is our hope and prayer that together the Christian Church in all its diversity will find ways to cooperate in the spirit of Micah, knowing what is required of us: to act justly, love mercy, and walk humbly with God.
Sincerely,
We Will Speak Out South Africa Faith Action Collective to End GBV
This letter has been endorsed by:
South African Chapter: Circle of Concerned African Women Theologians
Hope Africa
Centre for Black Thought and African Studies, Seth Mokitimi Methodist Seminary
Sonke Gender Justice
Kwanele Foundation
Ikhwelo Healers Collective
Ezabangoma Traditional Health Institute
Womxn with Vision South Africa
Additional Endorsements (Individual and Organisational):
