The Conduct of Financial Institutions (COFI) Bill has lost ground in the latest assessment of South Africa’s reform programme, with its progress score falling after it remained untabled in Parliament more than four months after the publication of its explanatory summary.
The October 2026 quarterly review of the Business Leadership South Africa (BLSA) Reform Tracker downgraded the Bill’s score from 87.5 to 75 for the July to September quarter. The tracker attributed the decline to the delay in the parliamentary process.
The setback came as the financial-sector reform index improved overall, rising from 88.1 to 89.5. Six other deliverables advanced during the quarter, with their average score increasing from 87.5 to 95. The financial-sector reform index consequently increased by 1.6%, from 88.1 to 89.5.
Progress included work on the draft Crypto Assets Manual, the transition from JIBAR to ZARONIA, the South African Reserve Bank taking over the Payments Association of South Africa’s payment-system role, and the FSCA’s Joint Standard 2 of 2024.
The COFI Bill was one of the negative developments identified in the tracker, recording a 12.5-point decline. Its score reflects BLSA’s assessment of progress against the reform timetable.
The Bill’s path to Parliament
The COFI Bill is intended to replace the current patchwork of sector-specific financial laws with a consolidated framework for market conduct regulation. It would give the FSCA a broader basis for supervising financial institutions, setting conduct standards and licensing entities, while aligning parts of the Pension Funds Act and strengthening protections for financial customers.
The Bill has been in development since 2018, with an initial draft published for comment in December that year and a revised version in September 2020. Cabinet approved it for submission to Parliament in April 2026, and a notice and explanatory summary were published in the Government Gazette on 17 April.
However, publication of the summary was a procedural step ahead of tabling, not confirmation that Parliament had formally begun considering the Bill. In an August 2026 analysis, the SA Legal Academy’s Policy Watch noted that the Bill had also not been submitted under Joint Rule 201 for parliamentary planning and information.
The BLSA tracker confirms that it remained untabled at the end of September.
Regulatory preparations continue
While the legislative process has yet to advance, the FSCA is continuing work on the regulatory framework that will support COFI’s implementation.
The Authority’s 2026 Regulation Plan, covering the period to March 2029, places COFI-related work at the centre of its programme. Planned work includes thematic frameworks covering fit and proper requirements, risk management and internal controls, complaints management and governance.
Read: COFI at the heart of FSCA’s 2026 regulation plan
The FSCA has also begun preparing for the licensing changes envisaged by the Bill.
Speaking at the FIA Advice Summit in October, Lezanne Botha, a senior manager in the FSCA’s Regulatory Framework Department, said financial institutions already licensed by the Authority would be relicensed by the FSCA rather than having to submit fresh applications.
Botha said the Authority was working on the licensing arrangements and intended to consult the industry before publishing its proposed approach. The Bill’s transitional provisions will determine how and when existing institutions move to the new framework.
Read: COFI: Existing licence holders won’t have to reapply
The FSCA has indicated that the transition will be phased, with different arrangements depending on the regulatory status and activities of the institutions concerned.
The preparations point to a regulatory framework taking shape while the legislation needed to underpin it remains outside Parliament. Until the Bill is tabled, the formal legislative process cannot move forward.
Other financial-sector reforms move ahead
The COFI Bill’s decline contrasted with progress elsewhere in the financial sector. Six deliverables advanced during the quarter, taking their average score from 87.5 to 95. The financial-sector reform index consequently increased by 1.6%, from 88.1 to 89.5.
Among the developments highlighted by BLSA was work on the draft Crypto Assets Manual, which forms part of the regulatory framework for crypto assets.
Progress was also recorded on the transition from the Johannesburg Interbank Average Rate (JIBAR) to the South African Rand Overnight Index Average (ZARONIA). The report identifies the conversion as one of the advancing deliverables. It also notes that a CME dress-rehearsal conversion took place on 7 October, ahead of the primary conversion of cleared rand-denominated JIBAR swaps, scheduled for 20 November.
The transition also faces a legislative hurdle. On 29 September, Parliament’s Standing Committee on Finance paused consideration of the General Finance Laws Amendment Bill after the Constitutional Court struck down the Public Procurement Act. The Bill includes provisions to support the move from JIBAR to ZARONIA, including a mechanism for replacing benchmarks in existing financial contracts.
Read: Parliament hits pause on urgent JIBAR transition Bill
Since then, Parliament’s legal advisers have recommended removing the procurement provisions and proceeding with the JIBAR-related amendments. The Committee had not adopted that recommendation by 15 October. On 30 October, the South African Reserve Bank said it was working with financial institutions on a backup plan in case the legislation was not passed by year-end. It said the delay would not change the direction of the transition and urged market participants to continue moving to ZARONIA.
JIBAR’s final publication remains scheduled for 31 December 2026. The date has not been reported as changed, but the parliamentary delay leaves uncertainty over whether the statutory arrangements for transitioning some existing contracts will be in place by then.
Another development was the South African Reserve Bank’s assumption of the Payments Association of South Africa’s payment-system role, as part of changes to the oversight and operation of the national payments system.
BLSA also recorded progress on a new FSCA standard. Its discussion of cyber resilience notes that, from 1 September 2026, financial institutions subject to the joint standards must use a common template issued by the Prudential Authority and FSCA to report material IT and cyber incidents to their regulators. The report highlights the growing importance of this oversight as banks become increasingly dependent on outsourced payment and data services, where disruption at a third-party provider can affect banking services even if the bank’s own systems have not been breached.
