The FSCA has published its three-year Regulation Plan for the period 1 April 2026 to 31 March 2029

On 3 July 2026, the Financial Sector Conduct Authority (“FSCA”) published its 2026 Three-Year Regulation Plan (“2026 Regulation Plan”), covering the period 1 April 2026 to 31 March 2029. The 2026 Regulation Plan outlines the FSCA’s strategic priorities and provides valuable insight into the initiatives that are expected to shape South Africa’s financial services regulatory landscape over the next three years.

The 2026 Regulation Plan reflects the FSCA’s continued commitment to developing a regulatory framework that is “robust, forward-looking, and aligned with both domestic priorities and international standards”, while signalling a gradual transition towards a more harmonised, outcomes-based, and principles-based conduct regulatory regime.

Central to this transition is the implementation of the Conduct of Financial Institutions Bill (“COFI Bill”), which the FSCA describes as a key reform that will fundamentally reshape South Africa’s conduct regulatory landscape.

Purpose and structure of the 2026 Regulation Plan

The 2026 Regulation Plan serves as a strategic planning tool intended to promote transparency regarding the FSCA’s future regulatory priorities and legislative agenda.

The FSCA’s regulation plans are reviewed annually to ensure that they remain responsive to changing market conditions, emerging risks and evolving regulatory priorities.

The 2026 Regulation Plan is structured into two sections:

• Section 2 reviews the regulatory outcomes achieved during the 2025/2026 financial year, as contemplated in the FSCA’s 2025 Regulation Plan. Importantly, the FSCA notes that good progress was made in relation to the COFI Bill, stating that “in late March 2026 the [COFI] Bill was officially approved by Cabinet for submission to Parliament”. On 17 April 2026, the Minister of Finance published a notice of the introduction of the COFI Bill to the National Assembly in the Government Gazette.
• Section 3 of the Regulation Plan which identifies the key regulatory focus areas and anticipated developments for the FSCA over the next three years, which is intended to provide financial institutions and other stakeholders with visibility of proposed regulatory developments, while allowing sufficient opportunity for engagement and consultation as new regulatory instruments are developed.

Overview of several strategic priorities for the period 1 April 2026 to 31 March 2029

The FSCA identified several priorities for the next three years, including (but not limited to):

• supporting the implementation of the COFI Bill and the transition to a harmonised conduct regulatory framework;
• strengthening financial markets regulation;
• developing Joint Standards on governance, outsourcing, operational resilience, and cloud computing;
• enhancing beneficial ownership transparency;
• advancing work on sustainable finance, open finance, and artificial intelligence;
• supporting the transition from JIBAR to ZARONIA; and
• continuing regulatory reforms affecting retirement funds, collective investment schemes, co-operative financial institutions, and payment services.

Industry players actively monitoring the FSCA’s regulatory plans will note that some of the above strategic priorities are not new.

The FSCA reiterates in the 2026 Regulation Plan that the key regulatory focus areas and anticipated developments for the FSCA over the next three years does not amount to a complete overhaul. Many of the priorities highlighted in the 2024 and 2025 Regulation Plan remain the same, however, there are revisions to the some of the timelines for certain projects.

For example, a few cross-sector regulatory framework developments from the 2025 Regulation Plan remain relevant in the 2026 Regulation Plan:

• The proposed Joint Standard Relating to Governance: This remains one of the FSCA’s flagship regulatory projects. The FSCA notes that technical work on the draft joint standard is continuing, with public consultation anticipated for the period January 2027 to June 2027.
• The proposed Joint Standard – Beneficial Owners of Financial Institutions: Pursuant to Chapter 11A of the Financial Sector Regulation Act 9 of 2017, the FSCA and the Prudential Authority intend to formulate a draft joint standard for public consultation and once settled, submission to Parliament. Subject to agreeing a timeline with the Prudential Authority, it is anticipated that public consultation could take place in the next 6 months. This joint standard is becoming increasingly important due to ongoing efforts to address the Financial Action Task Force (FATF) findings emanating from its mutual evaluation review of South Africa.
• Joint Standard – Requirements Relating to Third-Party Service Provision (outsourcing):  The FSCA notes that further technical work relating to this joint standard is expected to continue throughout 2026/27. It is anticipated that public consultation may take place between January 2027 to June 2027.
• Cross-sector licensing requirements: The FSCA has indicated that the timelines for public consultation on these draft requirements are not certain, but the 2026 Regulation Plan anticipates that public consultation on these draft requirements will take place in April 2028.

The rationale regarding why many of the priorities highlighted in the 2024 and 2025 Regulation Plan, remain the same, was set out in the 2026 Regulation Plan as follows: “As discussed in the 2025 Regulation Plan, an ongoing important consideration entails managing the volume of legislative changes and the impact that such continuous legislative reform may have on the sector, both from a planning and cost perspective. For that reason, the Regulation Plan attempts to limit, as far as possible, the introduction of new regulatory projects.”  

Noteworthy points relating to the COFI Bill and its status

The 2026 Regulation Plan indicates that once the COFI Bill is tabled in Parliament, the FSCA will provide technical support to the National Treasury to support Parliamentary deliberations, as deemed necessary.

Importantly, during the next three years, the FSCA will continue to focus on developing core, harmonised themed frameworks for the financial sector (Phase 2 of transitioning to COFI Bill), with public consultation on high-priority themed frameworks including (i) the draft Fit and Proper Framework, (ii) the draft Risk Management, Internal Controls and Control Function Framework; and (iii) the draft Complaints Management Framework. No anticipated dates are stated in the 2026 Regulation Plan for such themed frameworks, save that they will be introduced on a staggered basis.

Notably, the 2026 Regulation Plan states that (amongst others) no insurance or FAIS specific interventions are planned for the next three year period.

However, the FSCA notes that various insurance and FAIS related matters will be considered as part of the process focused on transitioning the existing sectoral laws to the COFI Bill framework, as part of Phase 3, which the FSCA states “will likely only advance in earnest once Phase 2 is far progressed”.

Although many of the proposed COFI Bill frameworks remain under development, the 2026 Regulation Plan provides useful insight into the direction of travel. Financial institutions should therefore continue monitoring developments closely, as consultation on the various themed frameworks is expected to continue during the planning period. These frameworks are likely to shape future conduct obligations relating to governance, customer outcomes, culture, product oversight, and broader conduct risk management.

What this means for financial institutions

A recurring theme throughout the 2026 Regulation Plan is the FSCA’s intention to move away from fragmented, rules-based regulation towards a more harmonised, principles-based, and outcomes-focused conduct framework. The FSCA views the implementation of the COFI Bill as central to achieving this objective and reiterates that its regulatory approach will increasingly focus on “fair customer outcomes,” supported by consistent governance and effective risk management across the financial sector.

While many of the initiatives identified in the 2026 Regulation Plan remain at policy development stage, the 2026 Regulation Plan provides financial institutions with a clear indication of the areas that are likely to receive increased regulatory attention over the coming three years. In particular, institutions should expect continued regulatory focus on (amongst other things):

• governance and board accountability;
• customer outcomes and conduct risk;
• outsourcing and third-party risk management;
• operational resilience and business continuity;
• cloud computing and technology governance;
• beneficial ownership transparency;
• artificial intelligence and data governance; and
• sustainable finance and open finance initiatives.

Looking ahead

The 2026 Regulation Plan gives financial institutions a useful roadmap for next phase of conduct regulatory reform in South Africa. Although many of the proposed reforms remain under development, the direction of travel is clear: the FSCA is moving towards a more coherent and harmonised regulatory framework centred on the COFI Bill and supported by cross-sector standards addressing governance, operational resilience, technology, financial integrity, and customer outcomes.

Although many of the initiatives identified in the 2026 Regulation Plan will be implemented over several years, the document provides financial institutions with an opportunity to prepare for the next phase of regulatory reform. Institutions that engage early with the proposed frameworks and continue strengthening their governance, conduct and operational resilience arrangements will be better positioned as these reforms progress through consultation and implementation.

The FSCA notes that “although the Regulation Plan contains a substantial volume of legislative interventions, these are expected to become significantly less frequent after the finalisation of the COFI Bill transition project”. As by that stage the FSCA is of the view that “the regulatory framework will have matured and will reflect an outcomes- and principles-based approach which allows for much more flexibility and negates the need for constant legislative change”.

For more information on the 2026 Regulation Plan, the COFI Bill, the proposed regulatory reforms and their practical implications for financial institutions, please contact Clyde & Co’s Corporate & Regulatory team.