Beneficial ownership updates and WOW product enhancements

As this is the first communication for the new year, please indulge me if I open with a quote. One of the American founding fathers, Samuel Johnson, stated that: “The true measure of a man is how he treats someone from whom he has nothing to gain.” There are few world leaders who share that ethos today.

FICA, KYC and UBO registers

While the General Law Amendment Act obligates all companies to lodge their beneficial ownership registers with CIPC annually, this information is only available to the state security cluster and not to third parties or the public. Beneficial ownership is a key component of KYC which creates a situation where one piece of legislation requires these institutions to establish the beneficial ownership for their clients, but another piece of legislation prevents them from accessing the same information. We are engaging with the relevant authorities to address this issue and will keep you informed of any progress.

Public Compliance Communication 59 from the Financial Intelligence Centre states that the use of independent third-party sources for KYC is not only permitted, but encouraged, and numerous accountable institutions use the WOW Data Feeds and WOWEB to help meet their compliance obligations under FICA. At the request of these users, we have made the following related improvements in 2025:

WOWEB:  New features and improved security

In 2025 we also introduced the following additional enhancements to WOWEB:

Reports update

The recently published report on Residential Facilities for the Elderly in South Africa indicates that the country is becoming an increasingly popular retirement destination for foreigners. According to 2024 data from the Department of Home Affairs, more than 3,600 retirement visa applications were submitted by foreigners from 112 countries, with an additional 1,686 applications pending. The top applicants were from the United Kingdom (UK), the United States (US), Germany, China, Switzerland, and the Netherlands.

The report also highlights the risk posed by the life right model, where retirees pay an agreed price for the right to occupy a unit for life, without acquiring ownership or title deed, particularly in cases of developer insolvency. This was highlighted by the 2024 Supreme Court of Appeal judgment in Herold Gie & Broadhead Inc v Harris N.O. and Others, involving the St Leger Retirement Hotel in Muizenberg (Western Cape). Although the Western Cape High Court initially ruled that the six affected retirees had a valid claim for refund, the SCA overturned this ruling. This precedent raises concerns about the adequacy of statutory safeguards for life rights holders who may lose their investment if the developer mismanages funds or enters liquidation.

The Defence Industry and Related Activities in South Africa report states that there are 61,006 active regular force (permanent force) and 8,386 reserve force (citizen force) members in the SANDF as of June 2025, according to the Department of Defence. Of the active regular force members, 10,219 were commissioned officers and 50,787 were other ranks (warrant officers, senior non-commissioned officers, junior non-commissioned officers). The average age of regular force members is 39, while the average reserve force member is 49. This is higher than the global norm, where most active-duty members are under the age of 30.

The report indicates that this sector is also underfunded. South Africa’s defence spending as a proportion of GDP is lower than the sub-Saharan average of just over 1% and the global average of 2.3%. Government’s budgeted allocation for defence declined to 0.74% of GDP in the 2024/25 financial year, from 1.1% in 2014/15.

Wishing you every success in 2026.