Sustainability reporting in South Africa: where it stands
Where sustainability reporting stands for South African companies, from CIPC's consultation to tagging, controls and assurance, and what to tell clients.
By Achekam · · 4 min read · For Accountants & audit firms in South Africa
A manufacturing client forwards a questionnaire from a European customer asking for its electricity use and emissions. A logistics client's bank has added "ESG information" to its annual credit review. A subsidiary of a listed group is told by head office to submit sustainability data by quarter-end. Each of them asks their accountant the same thing: is this compulsory now?
For most private South African companies, the honest answer is "not by CIPC, yet", followed quickly by "but people you depend on are already asking". This article sets out where the regulatory process stood at the time of writing, what is happening internationally that shapes the data clients will be asked for, and what a firm can usefully do now.
CIPC is still consulting
CIPC is running a Sustainability Reporting Market Sentiment Survey as part of a regulatory impact assessment, published under Customer Notice 06 of 2025. That is a consultation. A regulatory impact assessment is the stage where a regulator gathers views on whether and how to regulate; it is not itself a reporting rule.
For a firm, two things follow. First, do not tell clients there is a CIPC sustainability filing they must make, because the CIPC process described in that notice is at the consultation stage. Second, encourage clients who will be affected to take part, because the design of any future requirement is being shaped now.
Who is asking already
Regulation is only one source of pressure. In practice, the requests reaching South African clients come from:
| Who asks | What they typically want |
|---|---|
| Lenders | Information for credit and risk reviews |
| Export customers | Energy, emissions and supply-chain data |
| Group parents | Data in the group's own reporting format |
| Funders of non-profits | Impact and governance information |
None of these needs a South African law to make the request binding. A customer contract or a loan agreement does that on its own. The firm's role is to help the client answer accurately, from records, rather than with estimates nobody can support later.
When a request arrives, ask the client for the request itself rather than their summary of it. The definitions, the period covered and the format the requester wants decide which records are needed, and a questionnaire answered on the wrong basis is harder to correct than one answered late.
Tagged data is coming with the reports
XBRL International states that, starting in 2023 and accelerating quickly across the world, a wide range of securities regulators are obliging the use of XBRL in statutory sustainability disclosures. It also states that XBRL can be applied to any type of business data, including financial statements, sustainability disclosures, prudential reporting and tax returns.
The practical message for a client is that sustainability information increasingly travels as structured data, not as a narrative in a PDF. A client that keeps its energy use, fuel and waste figures in a spreadsheet with clear definitions and dates will find it far easier to answer a tagged request than one that keeps them in e-mails. For background on how tagging works in financial reporting, see what inline XBRL is.
Controls over the numbers
Sustainability figures are only as good as the process that produced them. COSO states that in 2023 it issued supplemental guidance to help organisations achieve effective internal control over sustainability reporting, using the COSO Internal Control-Integrated Framework.
That is useful framing for a client conversation. The same disciplines that make financial figures reliable apply here:
- a named owner for each figure;
- a source document behind it, such as a utility bill or fuel card statement;
- a review by someone other than the person who compiled it;
- a record of how estimates were made when actual data was missing.
A client that builds these habits now will be ready for assurance when it is asked for.
Assurance: the standard is not effective yet
On the assurance side, the IRBA's 2025 Handbook page lists International Standard on Sustainability Assurance (ISSA) 5000, General Requirements for Sustainability Assurance Engagements, in Volume III as a new standard not yet effective.
So a client asked for "assured" sustainability figures should be told plainly what kind of engagement is being offered and under which standard, and the firm should check the IRBA's handbook page for the current position before agreeing terms. The IRBA's separate ethics and independence standards for sustainability assurance are covered in IRBA ethics for sustainability assurance.
Using Achekam while the rules settle
Two points about Achekam matter here. First, Achekam does not pull a live feed of standards and regulatory changes; its Standards & Regulatory Updates page shows what its knowledge base records. A change in CIPC's position will not appear there automatically, so someone in the firm should own the job of checking.
Second, the hardest part of a sustainability questionnaire is usually getting the source documents. Staff can create, send and track requests to clients for documents, answers and confirmations in one RFI console, whichever screen the request was raised from. A request for a year's utility bills, fuel statements and waste collection slips is the same kind of request as one for bank statements, and tracking it in one place stops it falling between engagements.
For Nigeria and Kenya, where regulators have published their own roadmaps, see sustainability reporting roadmaps in Nigeria and Kenya.
What to tell clients this month
Tell them the CIPC process is a consultation, that customers and lenders may require information regardless, and that good records now will make any future requirement cheaper to meet. CIPC's page carrying the sustainability survey notice is the place to confirm the current stage of its process; check it before each client meeting where the subject comes up.
General guidance only, not advice on your own circumstances. Tax and payroll rules change: check the current position with the authority or your adviser.
