Nancy Andrews, Chairperson of IRFA

In his 2026 Medium-Term Budget Policy Statement (MTBPS) delivered on 21 October 2026, South Africa’s Minister of Finance, Enoch Godongwana, outlined government’s fiscal and policy priorities for the medium term. For the retirement fund industry, the most significant development was the continued progression of the Unclaimed Financial Assets Centralisation Framework.

The Minister confirmed that the framework, published for public comment on 20 August 2026, received broad support, particularly for measures aimed at improving the tracing of beneficiaries and reuniting unclaimed assets with their rightful owners. Further technical and policy work will be undertaken, with draft legislative amendments expected in 2027.

Implications for trustees

The proposed framework signals an increasing policy focus on the management of unclaimed benefits and the effectiveness of beneficiary tracing processes. Trustees should take the opportunity to assess the adequacy of their governance frameworks, the quality of member and beneficiary data, and the processes that support the identification and payment of benefits.

The evolving framework also underscores the importance of proactive oversight. Trustees should ensure that administrators and service providers have effective tracing strategies in place and that member records remain accurate, complete and up to date. Strengthening these foundations now will assist funds in responding effectively to future regulatory requirements.

Impact on pension fund administrators

For pension fund administrators, the proposed framework carries potentially significant operational implications. Increased emphasis is likely to be placed on data quality, record management, member tracing and reporting capabilities. Administrators may face greater scrutiny regarding the effectiveness of their tracing processes and the measures used to reunite members and beneficiaries with unclaimed benefits.

The reforms may also require enhancements to administration systems, data management practices and operational procedures. Administrators that continue to invest in data integrity, digitisation and efficient tracing capabilities will be better positioned to meet future regulatory expectations while supporting improved member outcomes.

IRFA’s continued engagement

The Institute of Retirement Funds Africa (IRFA) has been actively involved in the policy process and submitted extensive comments on the Draft Unclaimed Financial Assets Framework. In its submissions, IRFA highlighted the importance of balancing consumer protection objectives with practical implementation considerations, effective tracing mechanisms and the existing governance responsibilities of retirement funds.

IRFA supports initiatives aimed at improving the reunification of members and beneficiaries with their benefits, while advocating for a framework that is practical, cost-effective and capable of being implemented consistently across the industry.

As the process progresses, IRFA will continue to engage constructively with National Treasury and other stakeholders on both the refinement of the framework and the development of the accompanying legislative amendments.

Ongoing industry participation will be essential to ensuring that the final framework achieves its objectives while remaining practical for funds and administrators to implement.

Conduct of Financial Institutions (COFI) Bill

Notably, the MTBPS did not provide any update on the Conduct of Financial Institutions Bill, 2026 (COFI), despite its significance for the future regulation of the financial sector. The Bill was introduced into Parliament in April 2026 and seeks to establish a consolidated conduct framework for financial institutions, including retirement funds, administrators, insurers and financial advisers. It also proposes amendments to the Pension Funds Act and strengthens the conduct regulatory framework overseen by the Financial Sector Conduct Authority (FSCA).

While the absence of a COFI update in the MTBPS should not be interpreted as a shift in policy direction, it serves as a reminder that the Bill continues to progress through a separate legislative process. Given the wide-ranging implications for governance, licensing, conduct standards, customer outcomes and regulatory oversight, retirement funds and service providers should continue to monitor developments closely and prepare for the changes that COFI is expected to introduce.

Looking ahead

In the absence of major retirement fund policy or tax reforms, the MTBPS nevertheless signals the continued advancement of the unclaimed financial assets agenda. As the policy and legislative process unfolds, trustees and administrators should prioritise governance oversight, data quality and beneficiary tracing capabilities. A proactive and well-prepared industry will be better positioned to support the successful implementation of the framework and to fulfil its fiduciary responsibilities to members and beneficiaries.

Continued collaboration between industry stakeholders and National Treasury will be critical to ensure that the resulting legislative framework is both effective in achieving its public policy objectives and practical to implement across the retirement fund sector. At the same time, the industry should remain attentive to parallel regulatory developments, including the progression of COFI, which is expected to have a significant impact on the future conduct regulation of retirement funds and financial institutions more broadly.

ENDS