NCR 67(2) – They Closed the Door. We’re Opening It For You.
You did the work.
You built the practice.
You earned the designation.
Then a credit provider client asks you to perform their NCR assurance engagement and you discover that the regulation, not your competence, decides whether you can say yes.
For many Chartered Business Accountants in Practice, this is not just frustrating. It is commercial. It affects revenue, positioning, and professional standing.
Let’s unpack what is really happening and why this moment matters.
The Regulation That Draws the Line
Under the National Credit Act and its accompanying regulations, assurance engagements for non-audited credit providers are governed by Regulation 67.
Regulation 67 creates two distinct scenarios.
First scenario — Regulation 67(1):
If a credit provider is legally required to appoint an accounting officer or auditor under another law, then that appointed professional may perform the assurance engagement.
In practical terms, this means that if you are a CBAP who is formally and statutorily appointed as the accounting officer because the law requires that appointment, you may conduct the assurance engagement. Your authority flows from your statutory appointment.
Second scenario — Regulation 67(2):
If the credit provider is not legally required to appoint an accounting officer, then only members of five specifically named professional bodies may conduct the assurance engagement. .
CIBA is not currently listed under Regulation 67(2).
This means:
A CBAP who is the legally appointed accounting officer of a credit provider may perform the engagement under 67(1).
A CBAP who is not statutorily appointed (even if fully competent) may not perform the engagement under 67(2).
The restriction is structural. It is not about skill. It is about designation recognition within the regulation.
Why This Matters to a Small Practice Owner
If you run a small firm with 10 to 20 SME clients, you do not have the luxury of ignoring regulated income streams.
NCR assurance engagements are not once-off advisory discussions. They are recurring, compliance-driven services required by registered credit providers to demonstrate adherence to the National Credit Act and its reporting obligations.
That means:
Predictable revenue
Compliance-linked billing
Stronger advisory authority
When you cannot offer that service, one of two things happens. Either you refer the client elsewhere and lose revenue, or another practitioner begins building a relationship inside your client’s business.
In a very competitive market, where brand perception already creates pressure, losing a regulated service line weakens your competitive position.
This is not theoretical. It is practical.
CIBA’s Engagement With Regulators
CIBA has formally engaged both the Department of Trade, Industry and Competition and the National Credit Regulator regarding this exclusion.
The argument is grounded in fact:
CIBA is a recognised professional body under the National Qualifications Framework and related legislation.
Members operate in external practice.
Members are subject to CPD requirements, ethics oversight, quality-assurance processes, and mandatory professional indemnity.
Many CBAPs already conduct assurance-related or compliance-driven engagements in other regulated environments under statute and regulator-issued guidance.
The regulatory list in Regulation 67(2) has remained largely unchanged since 2006. The profession, however, has evolved. The credit market has evolved. The demand for compliance and assurance oversight has increased.
The question being asked is therefore simple: does a closed list still serve the regulator, the market, and consumers in today’s environment? In our view, no it does not.
What This Means Right Now
The current legal position is clear.
If you are a CBAP who is formally and statutorily appointed as an accounting officer because the credit provider is required by law to appoint one, then you may perform the assurance engagement under Regulation 67(1).
However, where a credit provider is not legally required to appoint an accounting officer, Regulation 67(2) applies. In those cases, only members of the specifically listed professional bodies may conduct the assurance engagement.
That is the boundary.
It does not question your competence. It reflects how the regulation is drafted.
However, regulatory frameworks are not static. Amendments to the National Credit Regulations are periodically proposed and reviewed. As the number of registered credit providers grows and compliance scrutiny increases, regulators must continually assess whether limiting assurance engagements to a closed list remains practical.
For CBAPs, this is not a moment for frustration. It is a moment for clarity and preparation.
The Strategic Opportunity
If CIBA members are recognised under Regulation 67(2) in the near future, the impact would be immediate.
You would be able to:
Add NCR assurance engagements as a recurring service line.
Deepen your compliance advisory footprint.
Strengthen your authority in regulated industries.
Increase billable income linked directly to statutory obligations.
More importantly, it would change how the market perceives you.
Practice rights shape positioning.
Positioning shapes pricing.
Pricing shapes sustainability.
Many CBAPs are already doing high-level compliance work for SMEs. NCR assurance would not require a new identity, only formal recognition of existing capability.
The Bigger Conversation About Practice Rights
That being said, this debate goes beyond one regulation.
Many CBAPs are first-generation business owners. Many operate in underserved communities. Many carry not only business responsibility but family expectations and community pressure.
Professional recognition is not only about prestige. It is about economic mobility.
When access to regulated work is limited, growth is limited. When recognition expands, opportunity expands.
The question is not whether CBAPs are capable. The question is whether the framework will evolve to reflect that capability.
Regulatory change requires persistence, evidence, and professional unity. CIBA’s engagement continues. The environment is shifting. The demand for assurance services is growing.
When change comes, it will reward those who are prepared.
You are already doing the work. Now ensure your professional standing supports the services you are ready to deliver.
Join CIBA and we’ll show you how to strengthen your practice rights, expand your income streams, and position yourself as the compliance authority your clients cannot afford to lose.
🔴 LIVE: 2026 Budget Speech Viewing & Expert Analysis
Understand the Budget as it happens. Know what to do next.
On 25 February 2026, South Africa’s National Budget Speech will set the tone for tax, compliance, and economic decision-making in the year ahead. CIBA invites you to a live Budget Speech Viewing & Expert Analysis Event, designed specifically for finance professionals who cannot afford to “wait and see” what it means.
Join us for a real-time viewing of the Budget Speech, streamed directly from Parliament, with live expert commentary translating policy announcements into clear, practical implications for your practice and your clients.
You will hear expert insights from Johan Heydenrych, Ettiene Retief, and Dr Frederich Kirst, as the Budget unfolds — not weeks later.
Whether you advise clients, manage tax risk, or lead financial decisions, this session helps you move from policy to action immediately. The event concludes with a cocktail networking session for in-person attendees.
📍 Venue: CSIR International Convention Centre, Pretoria
🕐 Time: 13:00 – 16:00 (Cocktails from 16:00)
💻 Attendance: In-person or Online
🎟️ Limited seats available
IN-PERSON: Register here
ONLINE: Register here
Don’t just hear the Budget. Understand it. Apply it.
#BudgetSpeech2026 #TaxProfessionals #FinanceLeadership #CIBA #SAEconomy
