Charismatic Churches Singled Out - ‘Nil Returns’ Under Spotlight

This article will count 0.25 units (15 minutes) of unverifiable CPD. Remember to log these units under your membership profile.

The CIPC issued a Compliance Checklist Report NPC but this is not a new compliance tool. They used the one they already have and published what six years of data is telling them about non-profit companies.

What is the Compliance Checklist?

The CIPC Compliance Checklist is a mandatory annual declaration, in place since 2020, covering 24 yes/no questions confirming whether a company complied with key sections of the Companies Act. It applies to all NPCs, and must be submitted within 30 business days of the company's incorporation anniversary. It is a standalone legal requirement separate from the annual return. Directors sign off on it, and submitting false information is a criminal offence under Section 215 of the Companies Act 71 of 2008.

Why did the CIPC issue this report now?

This report follows directly from Customer Notice 53 of 2025, issued in December 2025, in which the CIPC warned companies that it was cross-checking checklist responses against its own records and finding serious discrepancies. The NPC report is the next step: a public signal that the CIPC has identified a specific problem area and is putting the sector on notice.

Key Finding - Nil Turnover Declared

The focus falls on charismatic churches registered as NPCs. Their numbers have grown from 22 in 2010 to 261 by 2024. Of the 419 such churches still in business during the 2025 compliance year, 68% declared nil turnover in their annual returns. This is a figure the CIPC clearly does not accept at face value. The two main compliance failures identified are:

  • NPCs not applying their income and assets to the public benefit objects stated in their Memorandum of Incorporation, as required by Schedule 1 of the Companies Act

  • Directors receiving loans or financial benefits outside the limited exceptions the Act permits.

Beyond individual director misconduct, the CIPC also flagged broader misuse: legitimate NPC identities being used without consent for fraudulent fundraising, donor funds being redirected through fictitious contractors and inflated salaries, and insufficient background checks on staff and partners.

What are the key messages for your NPC clients?

The CIPC is not asking new questions. They are checking whether the answers already submitted hold up against the data they have. For any NPC you advise, the practical priorities are straightforward:

  • Declare accurate turnover figures, nil turnover on an active organisation is a red flag, not a filing strategy

  • Ensure all income and assets are used strictly for the organisation's stated public benefit objects

  • Do not provide loans or financial benefits to directors outside what the Companies Act permits

  • Maintain proper financial records and a clear accounting policy that accounts for all transactions, including cash donations

  • Complete the Compliance Checklist honestly and on time every year.

The CIPC has the data, the mandate, and the intention to act. For accountants advising NPCs, helping clients get this right is no longer optional advisory work. It is core compliance.

Next
Next

CEMS Is Live: CIPC Moves All Queries to Its New Enquiry System