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Refunds and Cancellations: Does the Consumer Protection Act apply to an intermediary?

If the intermediary is an individual or a juristic person with a turnover and asset value of under R2 million (at the time of the transaction), then they are fully protected by the CPA and can demand whatever has been paid out to the end supplier.

If the intermediary sits above the R2 million threshold, they would need to negotiate with the end supplier. Ideally, the intermediary would have had an indemnity in their supplier contract T&Cs, which stipulated that if you have to pay out a consumer in terms of the CPA, the end supplier should either reimburse the intermediary or be prepared to split the amount due so that there is fairness in the relationship.

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