COFI Readiness Checklist South Africa: What You Must Do Before the Bill Becomes Law

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COFI Readiness Checklist South Africa: What You Must Do Before the Bill Becomes Law

🚨 Why COFI Matters for Compliance Professionals

The Conduct of Financial Institutions (COFI) Bill will transform South Africa’s financial sector by embedding customer fairness, ethical leadership, and responsible conduct into enforceable law—not just guidelines.

Instead of navigating fragmented laws like FAIS, CISCA, and the Insurance Acts, COFI introduces a single, activity-based conduct framework for all financial institutions.

COFI will:

  • Consolidate multiple regulatory frameworks into one unified law

  • Define clear, enforceable outcomes for how products are designed, sold, and serviced

  • Hold boards and senior managers personally accountable for how customers are treated

In practical terms, this means:

  • Measurable conduct KPIs at every level of the organisation

  • Stronger product governance before and after launch

  • Transparent disclosures, redress processes, and complaints handling

  • Continuous testing to confirm customers receive fair value

Use the checklist below to evaluate your current state and take proactive steps before the FSCA begins enforcing COFI.

✅ COFI Compliance Readiness Checklist

1. Governance & Culture

COFI starts at the top. Ask yourself:

  • Has the board been briefed on COFI and its strategic impact?

  • Are conduct duties clearly assigned to accountable executives?

  • Does your culture actively support customer-centric outcomes (beyond policy)?

  • Do you conduct regular culture or conduct risk assessments?

➡️ If not: Schedule leadership training, assign conduct accountability, and include conduct risk in your ERM cycle.

2. Licensing & Business Activities

COFI introduces a single licence regime aligned to business activities.

  • Have you assessed how your current licences map to COFI categories?

  • Are all business activities properly aligned to regulated activities?

  • Are you ready to apply for a new or consolidated COFI licence?

➡️ Next step: Conduct a licence gap analysis and draft your application timeline.

3. Risk, Compliance & Conduct Frameworks

Policies must translate into action.

  • Do you have a Conduct Risk Management Framework in place?

  • Can you demonstrate how you identify, monitor, and fix conduct risks?

  • Is your compliance function resourced to oversee conduct obligations?

  • Are your escalation, whistleblowing, and disciplinary channels working fairly?

➡️ Take action: Align your frameworks with COFI principles. Set KPIs and develop a monitoring dashboard.

4. Customer Outcomes & TCF

COFI makes Treating Customers Fairly (TCF) legally enforceable.

  • Are you testing customer outcomes across the full product lifecycle?

  • Have you embedded TCF principles into processes and customer journeys?

  • Can you identify and support vulnerable customers?

  • Is your complaints process effective and outcome-driven?

➡️ Improve immediately: Define outcome indicators (value, suitability, clarity, service) and track them quarterly.

5. Product Oversight & Distribution

You must prove product value both before and after launch.

  • Do you have a formal Product Governance Policy aligned to COFI?

  • Are all products tested for suitability and value before launch?

  • Are you monitoring post-sale risks and customer feedback?

  • Are distributors and intermediaries adequately supervised?

➡️ Suggested fix: Create standardised product approval templates and audit tools for intermediaries/distribution networks.

6. Training, Awareness & Accountability

People make COFI work.

  • Has everyone in your organisation completed COFI training?

  • Do senior managers understand their personal accountability?

  • Are conduct KPIs tied to performance and incentive structures?

➡️ Quick win: Launch role-specific training and incorporate KPIs into performance reviews.

7. Transition Planning

You need a clear, coordinated plan.

  • Have you completed a COFI gap analysis across all functions?

  • Is a dedicated COFI working group or project team in place?

  • Have you engaged the FSCA or an industry body for timelines and guidance?

➡️ Next move: Build a milestone-based roadmap with assigned owners, reporting intervals, and a realistic budget.

📝 Evaluate Your COFI Readiness

  • ✅ Mostly “Yes” – You’re on track. Continue refining processes and stay aligned with FSCA updates.

  • ⚠️ Mixed results – Prioritise urgent gaps and roll out a phased action plan.

  • ❌ Mostly “No” – Now is the time to act. Assign internal champions or engage external experts.

🧩 How to Operationalise This Checklist

To make this tool work for your team:

  • Convert it into a traffic-light heatmap for leadership reporting

  • Track “Action Required” items using tools like Trello, Planner, or Jira

  • Schedule quarterly reviews and adjust as new FSCA guidance becomes available

💡 Let Navigate Help You Get COFI-Ready

At Navigate Compliance, we help financial institutions turn COFI compliance into competitive advantage. Here’s how we can support you:

✔️ Brief boards and EXCOs on COFI obligations
✔️ Run full gap assessments and build readiness roadmaps
✔️ Draft or enhance Conduct Risk, Product Governance & Complaints Frameworks
✔️ Deliver COFI-aligned training across all staff levels
✔️ Provide project management and transition planning

📩 Enquire now at info@navcompliance.co.za
🎓 Enrol in our Conduct Risk Course to get started today.

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