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Integrity Watch · Folio 02 Figures frozen

South Africa withdrew its draft AI policy over six invented sources. That was the least of it.

It also instructed the government to review the mandate of an institute that has never existed under that name — one the department itself helped found.

Ukweli is a tool that reads a document before it is published and looks for one thing: claims, citations, sources and quotations that cannot be checked.

We also keep Integrity Watch, a public register of documents that were corrected, withdrawn, refunded or punished after someone found made-up material in them. The register records what a document cost. This piece is about something else — what a document contains before anyone has counted the cost.

In April, South Africa's Department of Communications and Digital Technologies published a Draft National AI Policy in the Government Gazette, and the minister announced its withdrawal sixteen days later. The reason was public and specific: academic citations pointing to articles that do not exist. It is one of our South African entries, and the only one that is not a court matter.

We ran the withdrawn draft through Ukweli. What follows is what a checking tool sees in a document the press has already been through.

What was already established #

News24 found that at least six of the 67 entries in the draft's reference list pointed to non-existent articles. News24 reported that editors at the South African Journal of Philosophy, AI & Society and the Journal of Ethics and Social Philosophy confirmed the papers credited to their publications had never appeared in them. Those three journals are real; the articles attributed to them are not.

The department's account, given later by its director-general, Nonkqubela Jordan-Dyani, was that officials had worked from a Chilean document translated from Spanish into English, and that the invented references came across with it. The director-general told Parliament it "has been said that ChatGPT was used in as far as the editing of the document itself". Two departmental officials were placed on precautionary suspension — the minister and the department have said it was for failing to declare their use of AI.

Announcing the withdrawal, the minister said the draft contained "various fictitious sources in its reference list," that this "has compromised the integrity and credibility of the draft policy," and:

ON THE RECORD Minister Solly Malatsi · 26 April 2026
The most plausible explanation is that AI-generated citations were included without proper verification. This should not have happened. In fact, this unacceptable lapse proves why vigilant human oversight over the use of artificial intelligence is critical.
SAnews, 26 April 2026 View in the register →

That is the public record. Six bad references, a translation, an undisclosed tool, and a minister who has already said out loud what went wrong.

What our own tool found #

Ukweli looked up 70 citations in the document. The reference list carries 67 numbered entries, so the tool's count runs three ahead of it. One of the three we can account for: Inayatullah's 2008 paper, cited at footnote 23, never reaches the numbered list at all. The other two we cannot, and rather than supply a reconciliation we have not done, we are telling you that. For 21 it found the source and confirmed it. For 3 it found the source but the printed details did not match. For 32 it could not reach the kind of place that source would be listed at all — a dead end rather than a verdict. For 1 it asked a human to check against the original. And for 13, it searched and found nothing. That is 70.

Four of those thirteen are journal articles. They are these:

Four of the thirteen citations Ukweli searched for and could not find
Citation as printed in the draftJournal named
Babatunde, O., & Mnguni, P. (2023). Challenges and Opportunities in Regulating AI: Perspectives from South Africa. 2(3), 143–156AI Policy Journal
Burman, A., & Sewpersadh, K. (2022). Legal Frameworks for AI in South Africa: Balancing Innovation and Accountability. 41(2), 207–217South African Journal of Philosophy
Cavaliere, F., McGregor, R., & Hersh, M. (2022). Artificial Intelligence and Ethics in Emerging Economies: The Case of South Africa. 37(4), 565–583AI & Society
Smith, M., & Mahomed, R. (2021). The Impact of AI on Social Justice in South Africa. 18(3), 313–329Journal of Ethics and Social Philosophy

Three of those four journals are the three that News24's editors named. We have established nothing about the fourth, AI Policy Journal, and we are not claiming it does or does not exist. The contemporaneous coverage published all six of the citations News24 identified, numbered as they stand in the draft — sources 5, 9, 10, 19, 22 and 56 — and four of those six are the four above.

The tool did not get there by reading the news coverage. It got there by searching the academic databases and failing to find the articles — in three of the four cases having found the journal and the right volume first, and in the fourth not finding the journal either. And what it reported was "could not verify" — not "made up." Searching a database and finding nothing tells you the thing is not in that database. It does not prove the thing does not exist anywhere.

That distinction is the whole discipline. A tool that calls every miss a lie is useless to the person who has to defend the finding afterwards.

Where this piece calls the draft's six sources invented, that rests on News24's reporting, on the confirmations the editors of three of the named journals gave it, and on the department's own admission — not on our tool's output. Our output says "could not verify," and that is all it is entitled to say.

So on the part of the story the press had already done, the tool found four of the six the reporting had listed, reached them on its own, and stated its conclusion less strongly than the newspaper did. It did not reproduce the whole of the reporting, and we are not claiming it did.

The rest of what it found has not been reported.

The institute under a name it has never had #

The draft instructs government to "review the mandate of the Artificial Institute of South Africa."

We can find no organisation of that name, in any register or record we searched. The intended reference is almost certainly the Artificial Intelligence Institute of South Africa — AIISA — launched on 30 November 2022, with a hub at the University of Johannesburg and a second hub opened at Tshwane University of Technology in March 2023.

It was launched in partnership with the Department of Communications and Digital Technologies.

This is a department instructing itself, in a document published in the Government Gazette, to review the mandate of an institute it helped set up, under a name that institute has never had. No fake reference was involved. No translation was involved. A word went missing from the name of a real organisation and nothing in the public record suggests anyone raised it — not through the drafting, not through the departmental sign-off, not through publication, and not through sixteen days of public comment and press scrutiny. The comments submitted to the department are not published, so we cannot say what they contained.

Read next Folio 03 — Everyone read or heard about South Africa's AI policy that was withdrawn. How many people enquired if this was the first published draft?

It was not. The framework it was built on is still on the department's website today — and it says South Africa aims to overcome equality.

The citation that a translation cannot explain #

At footnotes 15, 20 and 22, and again as reference 24 in the bibliography, the draft cites this:

AS PRINTED Draft National AI Policy · reference 24
Goodfellow, I., Yoshua, B., & Aaron, C. (2017). Machine Learning Basics.
https://www.deeplearningbook.org/contents/ml.html
Appears four times, identically

"Machine Learning Basics" is Chapter 5 of Deep Learning, by Ian Goodfellow, Yoshua Bengio and Aaron Courville, published by MIT Press in 2016. It is one of the most cited textbooks in the field.

In the draft, Bengio's first name has been turned into a surname and given an initial, as though Yoshua were the family name. The same has happened to Courville. The result — "Yoshua, B." and "Aaron, C." — is not a spelling mistake and not a formatting slip. It is what happens when a name is reassembled by something that does not know which part is the family name. It appears four times, identically each time — and all four print the same working link, to the chapter itself. Whoever assembled the reference had the right page open.

This matters because of what it rules out. An invented citation could plausibly have arrived inside a translated Chilean document, as the department has said. A translation cannot turn two first names into surnames, get the year wrong by one, and print a chapter title as though it were the name of the book.

We are not claiming AI wrote this document. We do not need to. The department has already said tools were used and not disclosed. The point is narrower and firmer than an accusation: the explanation given in public does not account for everything that is in the document. Anyone with the draft and ten minutes could have worked that out. No published account records anyone doing so.

One further note, because it bears on how much weight these two findings can carry. Ukweli does not read a document once. It reads it several times over, through separate checks that cannot see each other's results — one looking at how the document is written and put together, another looking up whether the things it says can be confirmed anywhere. The misnamed institute and the inverted authors were each caught twice, by two of those checks working independently. That is not proof. But it is the difference between a finding and a hunch, and it is why these are the two we lead with.

The part nobody looks for #

Citations to articles that do not exist are the visible failure. They are also the rarest one.

The bigger problem is structural. Right across the draft, Ukweli picked out substantive claims with no source behind them at all — statements doing real work in a policy argument, with nothing supporting them.

Some are numbers. The draft says AI is "projected to contribute approximately USD $19.9 trillion to the global economy by 2030" — a precise figure, carrying the entire economic case, with no citation of any kind.

Some are comparisons. The draft says South Africa will set up AI accelerators "based on successful mentorship and funding schemes such as Singapore's," and that incentives will follow "examples from around the globe such as Canada's Strategic Innovation Fund." Both are real. Neither is cited; the Singapore comparison is not even named to a scheme; and nowhere does the document show how either performed or why it would work here. A foreign model is held up as proven and the proof is left out.

Some are foundations. The draft sets out four policy options and settles on none of them, saying a combination would be ideal. The case it puts for the first, an ethics-first approach, rests on the statement that emphasising ethics "aligns with South Africa's socio-historical landscape, where issues of fairness and inclusivity are particularly sensitive due to past inequities." That is true, and it is also a substantial historical claim being used to make the case for a policy option. It cites nothing. Not the census, not an inequality figure, not a commission report, not one source. It is uncontroversial enough that no reader would stop on it — which is exactly why it went in unsupported.

None of this is fabrication. All of it is a policy that cannot be checked by the people it will govern.

Ukweli reads a document before it goes out and tells you which of its claims, quotes and sources cannot be confirmed.

Put a document through it →

What this case is actually about #

The draft was withdrawn over six citations. Six citations were the part that could be checked by a journalist with a telephone and three editors willing to answer it.

The misnamed institute, the inverted authors, the $19.9 trillion with nothing behind it, the claims doing the heavy lifting with no source — none of those needed a fabrication to exist. They needed only that nobody did the last read before the document left the building. That read is not a skill problem or a diligence problem. On an 86-page draft carrying 67 references, it is a volume problem, and volume is the thing machines are good at.

It is worth saying plainly what the department then did, because it is more than many would have. It confirmed the failure within days of the reporting. The minister withdrew the draft, in public, in terms that conceded the point rather than managing it. Two officials were suspended. An expert panel was appointed to start again. Judged as a response, that is fast and it is candid.

But every one of those things happened after publication — and that is the whole argument. A withdrawal is what a document integrity failure costs once it is public. The sixteen days between gazetting and withdrawal are not the story; the last read before gazetting is, and it is the one step that never happened.

So the question worth asking is not how we stop AI making things up. These systems will keep producing convincing material that is not true. The question is how an unchecked claim stops becoming an official document — and in this case, an entry in the Government Gazette.

There is a live reason to ask it now. The policy is being rewritten. An expert panel chaired by Professor Benjamin Rosman of the University of the Witwatersrand is working on the redraft, the revised draft targeted for Cabinet in November 2026. It will be checked, hard, by everyone who read the coverage in April.

That single kind of failure — a source, a quote, a citation or a claim that nobody can confirm — is what Ukweli is built to find before a document is published.

How we checked #

Method note · 11 August 2026

The document we analysed is the full withdrawn draft as published: Government Gazette No. 54477, General Notice 3880 of 2026, published 10 April 2026, signed by Minister Solly Malatsi on 9 April 2026, 86 pages, comments due by 16h00 on 10 June 2026. We ran it on 11 August 2026 at 18:58, at Tier 3, Ukweli Certify — the same setting we later used for the 2024 framework. Ukweli counted it at 23,589 words and returned HOLD.

The minister announced the withdrawal on 26 April 2026, sixteen days after publication. The formal withdrawal notice was published later, on 12 June 2026, withdrawing the original notice "in its entirety effective from the date of publication." Both dates are correct for different things, and the "sixteen days" in this piece refers to the announcement.

Of the 67 numbered entries in that reference list, 28 are not literature at all but submissions made to the department during consultation, each printed as “Inputs to the South Africa National Artificial Intelligence Policy Framework”. We counted them ourselves off the gazetted PDF. Of the 70 citations the tool looked up: 21 confirmed against a source, 3 found but with details that did not match, 13 searched for and not found, 1 referred for a human to check against the original, and 32 that could not be reached at all because the kind of source involved is not well covered by the databases searched — which is a dead end, not a black mark.

We have not published a total count of problems found. That number moves depending on how a document is divided up for reading, so it describes the reading, not the document. The citation figures above are a record of what one check returned.

Every specific finding quoted here was checked against the published PDF itself, not just against the tool's stored results. The footnote numbers, the wording of the misnamed institute, the $19.9 trillion figure and the count of 67 numbered references were all read straight off the document. AIISA's name, launch date and partners were checked against the University of Johannesburg's own announcements; the Deep Learning citation against MIT Press; and the six-of-67 figure, the department's explanation and the suspensions against the published reporting.

Figures are frozen at the date above.

Sources #

Integrity Watch is a verified register, neutral by design. Every entry is confirmed against a reputable source, and if it cannot be confirmed, it is not listed. Ukweli is a content integrity platform built by The Orkestra.

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