The Art of
Discovery

The last weeks of the year are the natural time to take stock and set your practice up for 2027. Work through these seven checks before the office winds down.

1 Stay on top of your FSCA levies

Every authorised FSP pays annual levies to the FSCA, plus levies for the Ombud Council, the Financial Services Tribunal and the FAIS Ombud[8]. Levy amounts may change each year, so check the current gazetted amounts and your own FSCA assessment rather than relying on last year’s invoice.

2 Review compliance policies and registers

The General Code of Conduct requires a conflict of interest management policy that is published and reviewed annually, and a documented complaints management framework with accurate records of reportable complaints[3]. Records must be kept for five years and be available within seven days of the regulator’s request[3].

• Conflict of interest policy and gifts register reviewed and minuted.
• Complaints register up to date, with trends reviewed.
• Representative and debarment records accurate[11].
• FICA Risk Management and Compliance Programme updated, if you are an accountable institution[12].
• POPIA Information Officer registration and privacy notice current[13].

The FSCA plans to consult on COFI frameworks for fit and proper requirements, risk management and complaints management[14]. Current policies now will make that transition easier.

3 Check CPD and competency requirements

The CPD cycle runs from 1 June to 31 May, so you are now halfway through the 2026/27 cycle. Minimum hours are 6, 12 or 18 per cycle, depending on the classes and subclasses of business you are authorised for[15]. Evidence must reach the FSP within 15 days after the cycle ends, and the FSP must update its competence register within 30 days [15]. Before 31 December, check that:

• class of business and product specific training is complete and recorded for every product advised on[15]
• regulatory examinations were passed before appointment[15]
• your competence register is complete
• each person has a CPD plan for the rest of the cycle. Anyone behind can use the quieter January period to catch up.

4 Assess professional indemnity cover

FSPs must maintain suitable guarantees, or professional indemnity (PI) and fidelity cover, where required[3]. The minimum for Category I and IV FSPs is R1 million, rising to R5 million for some Category II, IIA and III FSPs[16]. A minimum is not the same as adequate cover. The FAIS Ombud can now consider claims of up to R3.5 million[17], so a R1 million limit may leave a gap. Before renewal, check:

• your limit of indemnity, and whether you could fund the excess
• run-off cover if you plan to retire, sell or merge
• that all representatives and key individuals are covered
• exclusions, including fines, cyber incidents and computer crime
• that your insurer knows about new products, mandates or AI tools used in advice.

5 Review cybersecurity and data protection measures

Digital banking crime losses in South Africa reached R2.4 billion in 2025[18]. Every FSP’s governance framework must cover electronic data security and internal and external cybersecurity[15]. Joint Standard 2 of 2024, in force since 1 June 2025, adds detailed requirements for in-scope institutions, including discretionary and administrative FSPs[19]. Under POPIA, security compromises must be reported to the Information Regulator and affected clients[13], now through the Regulator’s eServices Portal[20]. Quick checklist:

• multi-factor authentication on email and provider platforms, and tested backups
• system access removed for leavers, and devices updated and encrypted
• a staff phishing refresher before the festive season
• banking detail changes verified by phone, never by email alone.

6 Prepare your 2027 client service proposition

With 54 percent of employed South Africans not sure whom to turn to and 48 percent using general AI chatbots for financial guidance[5], a clear proposition shows clients why advice is worth paying for. Segment clients by need and value, define what each segment receives, check that fees cover your cost to serve, agree the scope and fees in writing[1] and test the result against the Treating Customers Fairly outcomes[2]. With notice of the Conduct of Financial Institutions Bill given in April 2026[14], a well-documented, outcomes-focused proposition is good preparation. Launch yours in January.

7 Check business continuity planning, especially December out-of-office

Every FSP must have a business continuity policy and back-up and disaster recovery plans[15]. December tests them: key people are away, but clients still face deaths, claims and emergencies. Remember that clients must give you six weeks to resolve a complaint before going to the FAIS Ombud, and that clock keeps running over the holidays[21].