UIF Registration: Must the Director Do It – or Can Your Accountant Handle It?
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A question recently was recently raised by CIBA practitioners on who may legally register an employer or employees for UIF. Different interpretations are often quoted in practice, with some suggesting that only directors may personally complete UIF registrations and that accountants, tax practitioners, or payroll professionals may not submit these registrations on behalf of a business.
If that were the case, it would significantly limit the role accountants play in helping businesses stay compliant. To clarify the position, we reviewed the relevant legislative requirements and set out our interpretation below.
What the law actually says
The Unemployment Insurance Act 63 of 2001 and the Unemployment Insurance Contributions Act 4 of 2002 require that the employer must register employees and submit the required information to the UIF. In terms of the legislation, the responsibility for registration and compliance therefore rests with the employer as the entity, rather than with a specific individual such as a director. In other words, the employer must ensure that employees are registered and that the required information is submitted to the UIF Commissioner. The duty is attached to the employer as an entity, not specifically to a director.
This means the law focuses on who is responsible for compliance, not who performs the administrative task.
Who may perform the UIF registration in practice
Because the duty lies with the employer, the employer may appoint someone to perform the registration on its behalf.
In practice, UIF registrations are commonly handled by:
Accountants
Payroll administrators
HR practitioners
Labour practitioners or other authorised agents.
This is consistent with how businesses manage most statutory compliance processes. Employers frequently rely on professional advisors to handle registrations, payroll submissions, and tax administration.
How the uFiling system works
The Department of Employment and Labour’s uFiling system also allows practitioners to manage UIF submissions once they are linked to an employer’s profile and authorised to act. The confusion often arises from the system’s approval process. You can refer to the uFiling System User Guide for more detail.
When a practitioner links to an employer profile, the system may send an approval request to the owner, director, or member of the organisation before the practitioner can act on the employer’s behalf. However, this approval step is simply an administrative control to confirm that the practitioner has permission to act. It does not mean that only a director is legally allowed to submit UIF registrations.
Why this matters for accountants
For practitioners, the key points are clear:
The legal responsibility lies with the employer, not with a specific individual such as a director.
Once authorised by the employer, a practitioner may perform the registration and submission on the employer’s behalf.
Supporting businesses with regulatory compliance is part of the accountant’s broader role in helping companies operate efficiently and focus on growth. As CIBA emphasises, reducing unnecessary compliance friction helps businesses create jobs and contribute to economic growth.
Restricting these functions unnecessarily would increase costs and complexity, particularly for small businesses that depend on professional advisors.
In summary
The legal responsibility for UIF registration lies with the employer.
The employer may mandate a practitioner or payroll administrator to perform the registration and submissions.
uFiling may require approval from a director or owner when linking profiles, but this is a system control — not a legislative requirement.
For accountants, UIF registration therefore remains a legitimate and valuable service you can provide to clients, provided you are properly authorised to act on their behalf.
