South Africa's Prudential Authority issued Directive 1 of 2025 at the outset of the year, formally removing the requirements governing bankers' acceptance returns from the Regulations relating to Banks and reissuing them under a standalone directive format. The change, which takes effect on 1 February 2025, marks a deliberate shift in the regulatory architecture for a specific class of reporting, giving the PA greater flexibility to update and refine requirements without the procedural demands involved in amending primary subordinate legislation.
The Prudential Authority operates under the South African Reserve Bank and is responsible for the prudential supervision of banks, insurers and other financial market infrastructures. The issuance of Directive 1 of 2025 is notable not only for its substantive effect on bankers' acceptance reporting but also for what it signals about the PA's approach to regulatory modernisation more broadly — a willingness to decouple specific reporting obligations from the consolidated Regulations relating to Banks when doing so enables more agile oversight.
SHIFT FROM REGULATIONS TO DIRECTIVE FORMAT
Under the previous arrangement, the requirements governing bankers' acceptance returns — including the forms, submission timelines and related instructions — were embedded in the Regulations relating to Banks, the principal subordinate legislation governing South African bank regulation. This structure, while providing regulatory certainty, limited the PA's ability to make targeted updates to reporting requirements without triggering a more cumbersome amendment process.
By reissuing these requirements under Directive 1 of 2025, the Prudential Authority converts them into a form of regulatory instrument that it can amend through its own processes rather than through the broader legislative amendment pathway. Directives issued by the PA carry binding force on regulated entities under the Banks Act, meaning that the substantive obligation on reporting banks remains enforceable, but the pathway for future modifications is considerably more streamlined.
The effective date of 1 February 2025 provides a short transition window for banks to adjust their internal reporting processes to reflect the new structure. In practical terms, the requirements themselves remain substantively the same; what changes is the instrument through which they are imposed and therefore the mechanism through which they may be updated in future.
UMOJA PLATFORM UNDERPINS REPORTING MODERNISATION
The directive also connects to a broader technological modernisation of the PA's data gathering infrastructure. The Umoja platform, which the SARB and the Prudential Authority use to collect regulatory returns and data from supervised entities, is central to the regulator's ambition to improve the timeliness, granularity and integrity of the data it receives from the banking sector.
Migrating specific reporting requirements into directive format enables the PA to align those requirements more precisely with the data fields and submission mechanics supported by Umoja, without being constrained by the form of the underlying Regulations relating to Banks. As the platform is developed further, the PA retains the flexibility to adapt its data collection to reflect evolving supervisory needs in a way that a static regulatory text would not easily permit.
For regulated banks, the directive format changes where they need to look for authoritative reporting requirements but does not alter their fundamental compliance obligations. The transition from Regulations relating to Banks to a PA directive is an administrative and architectural change rather than a substantive relaxation or tightening of the requirements themselves. Banks will be expected to familiarise themselves with Directive 1 of 2025 and ensure their reporting processes reflect its provisions from 1 February 2025.