Who may perform an independent review

Who is qualified to perform an independent review of a South African company's statements under regulation 29, by public interest score, and how to check.

By Achekam · 11 October 2026 · 4 min read · For Accountants & audit firms in South Africa

A company's statements arrive with a review report attached, signed by a practitioner the client found through a friend. The report looks professional. The question a careful reader should ask, and that a firm accepting the role should ask of itself, is whether that practitioner was allowed to sign it.

South African law does not let just anyone perform an independent review. Who qualifies depends on the company's public interest score, and the rule draws a line that catches out practitioners who assume one qualification fits every client.

Reviews under ISRE 2400 (Revised)

The Companies Regulations, as published in April 2011, require an independent review to be carried out in accordance with ISRE 2400. SAICA describes the engagement as limited assurance, consisting mainly of inquiry and analytical procedures, performed under ISRE 2400 (Revised) by a practitioner who was not involved in preparing the statements.

Two conditions therefore apply to every reviewer before qualifications come into it. The reviewer must perform the engagement under the standard, and the reviewer must stand outside the preparation of the statements. Why the second condition matters, and how firms separate the roles, is covered in why the preparer cannot also be the reviewer.

Scores of 100 or more

Under regulation 29(4), as SAICA restates it, where a company's public interest score is at least 100, the independent review must be done by a registered auditor or by a member of a professional body with the required accreditation.

For these companies, a close corporation accounting officer qualification is not enough on its own. The reviewer must be either on the IRBA's register or a member of a qualifying professional body. A firm should confirm which professional bodies qualify for this purpose from the regulations and the relevant notices, rather than assuming that any membership will do.

Below 100: close corporation accounting officers as well

Where the score is below 100, the regulations widen the field. In addition to registered auditors and members of a qualifying professional body, a person qualified to act as a close corporation accounting officer may perform the review.

That makes the score a gatekeeper for the reviewer as well as for the type of engagement:

The score is calculated for each financial year, so a reviewer who was qualified last year may not be qualified this year if the company has grown. Check the score before accepting every year's engagement, not only the first. The regulations quoted are the text as published in April 2011; check the current consolidated version for any later change.

Checking the IRBA register

Where the reviewer's qualification rests on registration as an auditor, it can be checked directly. The IRBA's Find an RA tool lets anyone search the register of registered auditors by surname, IRBA number, area, firm name or practice number. It is the quickest way to confirm that a reviewer, or an auditor, is on the register.

The same check is worth doing when the reviewer belongs to another firm, as in the opening example. A compiling firm that hands its client's statements to a reviewer the client found should confirm that reviewer's standing before the review starts, not after the report arrives.

For membership of a professional body, check with the body concerned. Record what was checked, when, and the result. A screenshot or printout of the register entry, dated, is better evidence than a note saying "confirmed".

Recording credentials in Achekam, and what it does not check

For a South African firm, Achekam keeps a record of practitioners' credentials. A partner, manager or administrator records each practitioner's professional body, membership standing with the date it was verified, and practising authority, with evidence. A credential that someone recorded about themself is flagged, so a second person can confirm it.

Two limits need to be understood:

• The IRBA badge is a label. On Partner Review & Signing, the "IRBA" badge is a label only. For a South African firm, Achekam checks the signer's partner role, not IRBA registration, and the regulator field is free text the firm types.
• Reviews from outside the firm. A firm can send a frozen set of statements to another firm on Achekam, or to an outside practitioner by e-mailed link, for an independent review under ISRE 2400 (Revised), with the reviewer's signed report bound to that version. For an audit, Achekam requires a partner the listing firm records as an IRBA registered auditor, but it does not check this with the IRBA.

So the firm's own check against the register and the professional body remains essential. Achekam records the result; it does not perform the check. Engaging another firm's reviewer is described in an independent review by another firm.

A short qualification check for every review engagement:

1. Confirm the company's public interest score for the year under review.
2. Identify the reviewer's qualification: registered auditor, member of a qualifying professional body, or close corporation accounting officer.
3. Confirm the qualification is enough for the score.
4. Verify it: the IRBA register for auditors, the professional body for members.
5. Confirm the reviewer took no part in preparing the statements.
6. Record the evidence and the date in the practitioner's credentials in Achekam.

Before signing any review report this season, run the six-step check for each engagement. Start with clients whose score is close to 100, where a change in the year could change who is allowed to sign.

General guidance only, not advice on your own circumstances. Tax and payroll rules change: check the current position with the authority or your adviser.