A petroleum wholesale licence is what the Department of Mineral Resources and Energy (DMRE) requires before a business can buy petroleum products in bulk from a licensed manufacturer and resell them to end users. It sits alongside the site and retail licences used to run a forecourt, but it covers a different activity entirely: bulk trading and distribution, not retail sale to motorists.
The licence is issued by the Petroleum Controller under the Petroleum Products Act 120 of 1977, on application using form DMRE-38. It is sometimes called a fuel trading licence in South Africa, since it is the licence a fuel distributor, bulk diesel supplier or wholesale fuel business needs to trade legally, rather than the licence a filling station needs to serve the public.
This page sets out the requirements, the step-by-step petroleum licence application process, what it costs, how long it takes, the documents you will need, and how the annual return and licence transfers work. If you would rather Insika managed the whole application for you, we can.
Petroleum wholesale licence requirements
Before the DMRE Petroleum Controller will consider a petroleum wholesale licence application, you need to show the department a genuine, compliant operation that can trade fuel in bulk. The requirements come from the Petroleum Products Act 120 of 1977 and its regulations, and in practice the department expects:
- A registered legal entity. Most applicants apply through a company registered with the Companies and Intellectual Property Commission (CIPC). If you have not registered yet, see our company registration service.
- Proof of tax registration. A SARS tax number and, where the department asks for it, a tax clearance certificate.
- Ownership and control information. The application form records the ownership and control percentages of the applicant, including any historically disadvantaged South Africans (HDSA) involved, since transformation is a factor the Controller weighs.
- Identity documents. Certified copies of ID documents for the applicant and directors. Non-South African applicants must submit a permanent residence or work permit and proof of residence in South Africa.
- Financial capability. Evidence that the business can fund and sustain bulk fuel trading, usually supported by a business plan and a financial capability assessment.
- A signed declaration that the business complies with the national, provincial and local legal requirements that apply to its operations.
None of these requirements are unusual on their own, but a wholesale licence application is refused or delayed more often for an incomplete or poorly evidenced submission than for any single missing document. Get the entity, tax and financial documents right before you complete form DMRE-38.
What a petroleum wholesale licence lets you do
A petroleum wholesale licence lets you buy petroleum products in bulk, defined as 1 500 litres or more per transaction, from a licensed manufacturer, and sell that fuel on to end users. In practice this is the licence for a fuel distributor, a bulk diesel supplier to mines, farms, construction sites and transport fleets, or a wholesale fuel business supplying other licensed operators rather than the public at a forecourt.
It is a distinct licence from the other categories in the Petroleum Products Act licensing chain. A retail licence permits the actual sale of fuel to motorists at a forecourt, and a site licence permits a petrol station to be established on a specific piece of land. A manufacturing licence covers refining and blending. The Act restricts cross-holding between these categories, so a wholesale licence holder is generally not also permitted to hold a retail licence for the same operation, to stop one company controlling too much of the fuel supply chain.
If your business model is bulk supply to other operators, this is the licence you need. If you intend to sell fuel directly to the public from a forecourt instead, you need the site and retail licences, and Insika can confirm the right combination before you apply.
How to apply for a petroleum wholesale licence step by step
The petroleum licence application process runs through the department in a fixed sequence. This is how a typical wholesale licence application moves from preparation to grant.
- Confirm your business case and prepare your documents
Set out how the business will source, store and sell fuel in bulk, including a business plan and financial capability assessment. This is also where you register your company, if you have not already, and gather your tax and ownership information.
- Complete form DMRE-38
Complete the Application for Wholesale Licence (DMRE-38), covering the applicant's identity and entity details, the physical address of the operation, ownership and HDSA information, and the required declarations.
- Lodge with your DMRE regional office
Submit the completed form and supporting documents to the Department of Mineral Resources and Energy regional office responsible for your area.
- Publish notice in four newspapers
Once the department has reviewed your submission, it sends a letter instructing you to publish a notice of the application in four newspapers, so interested or affected parties can raise objections.
- Submit proof of publication
Send the department proof that the notice ran in all four publications. This is what starts the clock on the department's statutory decision period.
- Decision and licence issued
The department must decide within about 90 days of receiving proof of publication. On approval, you pay the applicable fee and receive your wholesale licence, valid for as long as the business continues to operate.
Petroleum wholesale licence cost
The department's own fees for a petroleum wholesale licence are modest. The real cost sits in preparing a properly evidenced application, the newspaper notice, and any professional help you use. The figures below are indicative for budgeting, confirm the current DMRE fees with your regional office before you lodge.
| Item | Indicative cost |
|---|---|
| DMRE application fee (form DMRE-38) | R1 000 |
| Notice of application in four newspapers | R2 000 - R8 000 depending on the publications used |
| Business plan and financial capability assessment | R5 000 - R15 000 |
| Annual licence fee once granted (form DMRE-30) | R500 per year |
| Insika professional fee (indicative) | R15 000 - R35 000+ |
| Indicative total to prepare and lodge a new application | R25 000 - R60 000+ (excluding the annual renewal fee) |
How long does a petroleum wholesale licence take
The department must decide on a complete application within about 90 days of receiving proof that your notice ran in all four newspapers. That figure is a statutory outer limit on the decision itself, not the whole process. Getting to the point where the 90-day clock starts, preparing your documents, lodging the application, the department's initial review, and running the newspaper notice, commonly adds weeks or months before that period even begins.
- Faster: a complete application with clear ownership, tax and financial information, no queries from the department, and a newspaper notice that runs without delay.
- Slower: incomplete HDSA or financial capability information, queries that need a resubmission, or delays in placing the newspaper notice.
A realistic overall budget is a few months from a complete, correctly prepared application to a licence in hand. Build this into your business plan and do not commit to fuel supply contracts that assume trading before the licence is granted.
Documents you will need
The exact list can vary by DMRE regional office, but most petroleum wholesale licence applications call for the documents below. Having them ready and correct is the single biggest factor in avoiding delays.
Annual return and licence validity
A petroleum wholesale licence does not expire on its own. It remains valid for as long as the business continues to operate. What keeps it in good standing is the annual return: every licensed wholesaler must submit business information to the department each year on form DMRE-30, together with the annual licence fee, currently R500 (confirm the current fee and due date with your DMRE regional office).
The annual submission typically covers the volumes of fuel bought and sold, employment and transformation information, and progress against the industry's charter objectives. Missing the annual return puts the licence at risk, since the department can act against a licensee that fails to keep its information current.
Licence amendments, transfers and trading without a licence
A wholesale licence is granted to a specific entity for a specific operation. If your business changes materially, a change of ownership, a change of the entity's registration details, or a change in how or where you operate, you need to notify the department and, in most cases, apply to amend or transfer the licence rather than assume it carries over automatically. Buying an existing wholesale operation is no different: the licence needs to be transferred into the new owner's name before that owner can lawfully trade under it.
Trading fuel wholesale, buying and selling in bulk quantities, without a valid licence is an offence under the Petroleum Products Act. The department can also act against a licensee that trades outside the terms of its licence, for example by selling to the public instead of to end users in bulk. The cost of getting the licence right up front is far smaller than the cost of being found trading unlawfully.
Official sources
This guide is based on the current rules published by the relevant South African authorities. Always confirm the latest fees and requirements with the office that applies to you.
