SAICA: Ultimate Beneficial Owner (UBO) Guide

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SAICA: Ultimate Beneficial Owner (UBO) Guide

• 29 May 2026
• Miscellaneous
• South African Accounting Academy

Summary:

The South African Institute of Chartered Accountants (SAICA) has reminded members about an Ultimate Beneficial Ownership (UBO) Guide that was published in December 2025, and is now available on their website.

Article:

Legislation has recently been amended relating to the requirements of Ultimate Beneficial Ownership (UBO).

The understanding of the requirements is complex yet important to ensure regulatory compliance. As members of SAICA, members are owners of firms, directors of companies, members of close corporations, employees of various types of organisations and offer services to clients and will be impacted by the requirements of the new beneficial ownership regime.

South Africa’s grey listing in February 2023 (South Africa was removed in October 2025) required strengthened controls relating to UBO to better respond to the risks of money laundering (ML), terrorist financing (TF) and proliferation financing (P”). Accountable Institutions (AIs) are required to maintain accessible records of the UBOs of its clients and to provide this information to competent authorities including the Financial Intelligence Centre (FIC), this is an obligation set by the Financial Intelligence Centre Act (FICA).

The AI should obtain accurate, adequate, and up to date beneficial ownership (“BO”) information on its clients. Through identification and taking reasonable steps to verify the BO, the AI must be satisfied that it knows “who” the BO is, and “why” or “how” the person is a BO. This requires understanding of the BO interest.

This guide is based on selected sections of the Financial Intelligence Centre Act (as amended and referred to as the (“FICA”), the Companies Act, the Trust Property Controls Act (the Acts) as well as further supporting local and international laws and guidance.

In the interest of brevity, the guide summarises certain provisions of the Acts and the supporting local and international laws and guidance’s or refers to extracts.

It is important that members understand the importance of ensuring regulatory compliance in relation to UBO disclosure and encourage enhanced risk management to respond to ML, TF & PF risks.

Click here to download the 33-page document:

https://saicawebprstorage.blob.core.windows.net/uploads/resources/SAICA-Ultimate-Beneficial-Ownership-Guide.pdf 

Relevance to Auditors, Independent Reviewers & Accountants:

• Auditors, Independent Reviewers and Accountants should adhere to the tax consequences regarding Notional Input VAT.
• Auditors, Independent Reviewers and Accountants should always be aware of the latest publications issued by regulators, professional bodies and standard-setting boards, such as SAICA, as well as the contents of any practical considerations regarding Beneficial Ownership – as contained within this guide.
• Auditors, Independent Reviewers and Accountants should be aware of the latest publications and guidance issued by regulators, such as the FIC – to enable their assessment of accountable institutions’ compliance with FICA.
• As a TCSP (which is an accountable institution), the firm also needs to comply with FIC, and the resulting Beneficial Ownership requirements.
• When advising clients or performing this function on their behalf, practitioners should be aware of the finer details and specific guidance on Beneficial Ownership.

Relevance to Your clients:

• Relevant companies and CCs (accountable institutions) should be aware of the latest publications and guidance issued by regulators, such as the FIC.

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