The concern follows the publication of draft amendments to the regulations for comment until October 14.
Global Migration SA managing director Leon Isaacson said though the law has been in force since June 2014, the department had since issued a few directives to simplify it.
“The department has tried to sort out the confusion without taking on bigger issues,” he said.
He said the issues that had been overlooked included language schools being unable to admit foreign students, lack of capacity to register people bringing critical skills to the country or the absence of professional associations to register some of those critical skills and issues between the department and its labour counterpart.
The latest travel report by Euromonitor found that visits to South Africa declined by 7% in 2015 to 8.9-million trips.
The department said it had an obligation to take the input of the affected parties.
“The department is committed to the amendment, which reflects the consultative process.”