On 6 August 2025 the Financial Sector Conduct Authority (FSCA) officially introduced ‘Conduct Standard 2 of 2025: Conditions Prescribed in respect of Pension Fund Benefit Administrators’ (Conduct Standard). The Conduct Standard significantly enhances the regulatory framework applicable to benefit administrators of retirement funds governed by the Pension Funds Act, 1956.
The Conduct Standard marks a major upgrade from the previous framework outlined in Board Notice 24 of 2002: ‘Conditions determined in respect of Administrators acting on behalf of Pension Funds’ (Board Notice), which is now being phased out.
The intention is for the Conduct Standard to ultimately replace the Board Notice entirely – giving the Board Notice a much-needed retirement. In ‘Communication 15 of 2025 (RF)’ released with the Conduct Standard, the FSCA advised that it identified the need to strengthen the existing regulatory framework set out in the Board Notice.
Alongside the Conduct Standard, the FSCA has also published ‘FSCA RF Notice 10 of 2025’, which sets out the required format submissions to the FSCA under the Conduct Standard.
While some of the requirements in the Conduct Standard echo those in the Board Notice, it also introduces clearer expectations, tighter controls, and several new requirements. Notably, the Conduct Standard:
- introduces fit and proper requirements for benefit administrators and their key persons;
- requires benefit administrators to establish and maintain an effective ‘complaints management framework’ to ensure the effective resolution of ‘complaints’ (as defined in the Conduct Standard); and
- mandates new requirements for Service Level Agreements between retirement funds and their benefit administrators.
- Most provisions in the Conduct Standard came into effect on 6 August 2025, while others will take effect later. The rollout timeline is in paragraph 40(3) of the Conduct Standard.
Paragraphs 5 to 13 of the Board Notice were repealed as of 6 August 2025, with paragraphs 1 to 4 and 14 scheduled for repeal in in August 2026.
