The FSP compliance checklist — licensing, fit and proper, CPD and financial statements

An FSP that can produce its FSCA licence conditions, an up-to-date representative register, CPD records for every key individual and representative, its last submitted financial statements and proof of levy payment is covering the ground the FSCA checks first.

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

In short

Fit and proper requirements apply continuously to the FSP, every key individual and every representative, not only at licensing.
The representative register must be kept current on the FSCA's FAIS Online system.
CPD records need a policy, a training plan per person, and evidence the CPD provider is accredited.
Category II, IIA and III FSPs carry extra declarations — liquidity calculations and investments under management.

Licensing and governance file

Current FSP licence and licence conditions as issued by the FSCA.
Category classification (I, II, IIA, III, IV) and the classes and subclasses of business authorised.
Key individual appointments, approvals and fit and proper records.
Representative register maintained and updated on FAIS Online.
Debarment records for any representative debarred, and proof the FSCA was notified.
Professional indemnity and fidelity guarantee cover, where the FSP's category requires it.

Fit and proper and CPD file

CPD policy under Chapter 4 of the Fit and Proper Requirements (Board Notice 194 of 2017).
A CPD training plan per key individual and representative for the current 1 June–31 May cycle.
Verifiable CPD certificates showing hours completed against the applicable minimum (6, 12 or 18 hours, plus 6 hours for crypto asset activities where relevant).
Confirmation that CPD providers used are accredited by a recognised professional body.
Competence register updated with CPD activity from the closed cycle.

The FSCA has flagged that FSPs remain responsible for verifying their CPD providers' accreditation status — a certificate from an unaccredited provider does not count.

Financial and levy file

Annual financial statements submitted within four months of financial year end (FAIS Act 37 of 2002, section 19).
Signed Annexure A declaration, where the FSP is exempt from the audit requirement.
FAIS Act 37 of 2002, section 19 auditor's report, where client funds or premiums are received into a separate account.
Proof of payment of the annual FSCA and Ombud levy invoice.
For Category II, IIA and III FSPs: the Liquidity Calculation Declaration (Form A), submitted within 45 days after every half-year end.

Client-facing conduct file

Record of advice and disclosure documents for financial services rendered.
Complaints register and evidence of the FSP's internal complaints resolution process.
POPIA processing records for client personal information.

Frequently asked

Do sole proprietor FSPs need an auditor?

Only if they receive client funds or premiums, or if the FSP is a company rather than a sole proprietorship or close corporation. Otherwise unaudited statements with a signed Annexure A are accepted (FAIS Act 37 of 2002, section 19).

Does a representative who resigns mid-cycle still need to complete CPD?

CPD applies for the period the person is appointed. The FSP should keep records showing what was completed up to the date of resignation or debarment.

What is the Liquidity Calculation Declaration and who submits it?

It is Form A, required from Category II FSPs that collect premiums and all Category II, IIA and III FSPs, submitted within 45 days after each half-year end based on the FSP's own financial year.

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.