The full NCR compliance checklist for credit providers and debt counsellors

A credit provider that can produce its NCR registration certificate, its last three renewal fee payments, its Form 39 submission history and its most recent compliance report is in a defensible position. A debt counsellor's file looks similar, with the addition of Form 16 application records and proof of the branch fee for every registered location.

Reviewed by TefCo Compliance Research — last verified 15 September 2026.

In short

Registration and renewal proof come first — an inspector's opening question is usually whether the registration is current.
Form 39 and the compliance report are separate filings on separate clocks and both need a retained submission trail.
Credit providers that supply data to credit bureaux have separate onboarding and reporting obligations under the Regulation 19(13) guideline.

Registration and renewal

Current NCR registration certificate (NCRCP for credit providers, NCRDC for debt counsellors, NCRCB for credit bureaux).
Proof of the current year's registration renewal fee, paid by 31 July, referenced with the correct registration number.
Records of any penalty paid during a grace period, and confirmation registration was not automatically lapsed.
Branch fee payment proof for each additional location, where applicable.

Statutory reporting

Form 39 statistical returns — quarterly if annual disbursements exceed R15 million, otherwise the single annual return by 15 February.
Annual compliance report, filed within six months of financial year end.
Annual financial and operational return, where required under the National Credit Regulations.
Any assurance engagement report requested by the NCR.
Records showing information reported is accurate, complete and prepared on the same accounting basis as the entity's own financial statements.

The National Credit Regulations give the NCR the right to demand an analysis of any item in a submitted return within 20 business days of a request. Keep supporting workings, not just the filed form.

Credit bureau data reporting

Confirmation of onboarding to the Data Transmission Hub if the entity is a data contributor under the Regulation 19(13) guideline.
Ongoing monthly data submission records to credit bureaux.
Fee payment records where a Fee Guideline applies to data transmission services.

Debt counsellors specifically

Form 16 application records for each consumer taken into debt counselling.
Written disclosure of all fees to the consumer before signature.
Registration certificate displayed at the place of practice, or available for inspection.
Records of restructuring proposals and confirmation by magistrate's court or National Consumer Tribunal order.

Frequently asked

Does a credit provider under the R15 million disbursement threshold still file Form 39?

Yes — annually, by 15 February, rather than quarterly. There is no exemption from Form 39 based on size, only a difference in frequency.

What is the first thing the NCR checks in a compliance review?

Current registration status and renewal fee payment history, since a lapsed registration affects the validity of every agreement concluded during the lapse.

Do credit bureaux have the same Form 39 obligation as credit providers?

Form 39 is a credit provider return under regulation 64. Credit bureaux have separate reporting duties, including under the Regulation 19(13) data-reporting guideline.

Sources

TefCo Corporate Compliance (Pty) Ltd is a compliance management platform, not a legal, tax or advisory firm. This guide is general information, not advice. Fees, dates and thresholds change — confirm current figures with the regulator before you rely on them.