All other information requests must be finalised within 21 days from the date of the request. AIPPA does
not differentiate between urgent and non-urgent information requests. The reduction in the number of days
within which information requests have to be dealt with is welcome and the timelines are similar to the
timelines found in the Model Law11.
Section 8 of the Bill requires that responses for information requests should be in writing and the response
must state whether the request is granted or denied. Where the request is granted, the information officer
must furnish the information in the requested format. Where an information request is denied, adequate
reasons must be furnished stating reasons for the denial. The response should also cite legislation upon
which the denial is based and lastly, the applicant must be informed of their right to appeal the refusal.
Section 9 gives information officers the ability to extend the period within which they respond to
information requests. These requests are, however, only possible under the following strict conditions:
(a) the request is for a large amount of information or requires a search through a large amount of information
and meeting the original time limit would unduly interfere with the operations of the entity concerned; or (b)
consultations that cannot reasonably be completed within 21 days are necessary to
comply with the request12.

The information officer must furnish adequate reasons for extending the time to process a request. These
reasons must be provided to the applicant in written form. This notice must also include the period of the
extension. One of the major criticisms of the current request mechanism under AIPPA is that there is
possibility to continuously prolong the processing time for requests. It is therefore welcome that the Bill
does limit the grounds upon which requests can be extended. Where only part of the requested data can
only be provided after the initial 21-day period, the information officer must provide the information that
s/he can within the 21-day period.
In terms of Section 12 of AIPPA, the head of a public body may transfer a received request for information
to another public entity better positioned to respond to a request for information. This transfer must be made
within 10 days of receiving the original request for information. The entity that the request for information
is transferred to has to respond to the request within 30 days of receiving it.
The gazetted Bill does not contain a provision that permits the transfer of requests from one entity to another.
The Bill’s current form means that an applicant who submits a request for information to a wrong or less
relevant entity would have to personally investigate or enquire as to the correct or more suitable entity and
11
12

Sections 15 and 16 of the Model Law on Access to Information for Africa
Section 9(1)(a) and (b)

10

Select target paragraph3