Knowledge Centre
Accounting Officer
1. What You Need to Know
Accounting Officer (AO) appointments are legally recognised in South Africa. Under Section 60 of the Close Corporations Act (1984), a Business Accountant in Practice, BAP(SA) or Chartered Business Accountant in Practice (CBAP) is recognised as an AO. They can issue reports on financial statements and other information for close corporations and entities where statutes require it. Their authority comes from both statutory recognition and CIBA membership.
2. Who Can Be an Accounting Officer?
In principle, an accounting officer must be a member of a recognised professional body such as CIBA, that, as a condition of membership, requires appropriate accounting-related qualifications and subjects, and enforces professional standards, ethical conduct, and ongoing compliance obligations. According to the Close Corporations Act 69 of 1984, qualifying members of the following recognised professional bodies can perform duties as accounting officers:
The South African Institute of Business Accountants (SAIBA)
The South African Institute of Chartered Accountants (SAICA)
Auditors registered in terms of the provisions of the Auditing Profession Act, 2005(CA)
The Southern African Institute of Chartered Secretaries and Administrators (ICSA)
The Chartered Institute of Management Accountants (CIMA)
The South African Institute of Professional Accountants (SAIPA)
THE IAC who have obtained the Diploma in Accountancy (IAC)
The Association of Chartered Certified Accountants (ACCA)
The Chartered Institute of Business Management (MCIBM)
The South African Institute of Government Auditors (SAIGA).
CIBA members that have obtained the designation Business Accountant in Practice, BAP(SA) or Chartered Business Accountant in Practice (CBAP) are recognised as accounting officers.
3. What Accounting officers Do
In term of section 62 of the Close Corporations Act, the accounting officer’s report consists of:
Factual findings related to accounting records i.e., whether the financial statements agree to the accounting records.
A conclusion on the appropriateness of the accounting policies as applied.
Factual findings related to a contravention of the Close Corporations Act, i.e. if the accounting officer becomes aware of a non-compliance, the nature of this contravention should be described in the report.
4. Why It Matters to You
Being appointed as an accounting officer isn’t just a regulatory formality, it’s a recognised, trusted role within South Africa’s financial reporting ecosystem. As an accounting officer, your report:
Ensures legal compliance and credibility of SMEs and other entities.
Required by law for all close corporations.
Recognised across multiple Acts (schools, trusts, co-operatives, NPOs, etc.).
Provides funders, regulators, and owners with confidence in financial statements.
Opens up new client opportunities for CBAPs in practice with relatively low engagement risk.
5. Frameworks, Standards, or References
AO engagements are anchored in statutory law and international standards.
Professional standards
The professional standards and guidance below apply for accounting officer engagements:
ISRS4400 Revised Agreed Upon ProceduresProvides the framework for performing factual findings procedures, which form the basis of Accounting Officer reports. IESBA Code of Ethics
Sets out the ethical principles AOs must follow, including integrity, objectivity, and professional behaviour.
ISQM1 Quality Management Framework
Requires accounting practices to implement quality control systems to ensure consistent, reliable performance of AO engagements.
CIBA Guides and Templates
The full version of the guide and templates relating to AO engagements you can download from under ‘Free Educational Guides’ after logging into your CIBA member profile.
CIBA Member Guide to Accounting officers Reporting Engagements
Provides an interpretation of ISRS 4400 for South Africa.
Engagement Letter for Agreed Upon Procedures
Required to define scope, extent, and result (reduces engagement risk).
Illustrative Report for AO Engagements
Provides the format for the AO report in line with ISRS4400.
Statutory Recognition
AO engagements are recognised in various pieces of legislation, either through explicit statutory requirements or accepted regulatory practice.
Close Corporations Act 69 of 1984Requires all close corporations to appoint an AO to issue a report confirming the financial statements agree with the records and noting any contraventions of the Act.
Non-Profit Organisations Act, 71 of 1997
Requires registered NPOs to appoint an AO to report on whether the financial statements are consistent with the records and whether the NPO complies with its constitution and the Act.
Immigration Act No. 13 of 2002
Requires business visa applicants to demonstrate that their business is operational and financially sound, which may include a report by an Accounting Officer.
Recognises CIBA as a professional body whose members are authorised to issue AO reports for business visa applications.
South African Schools Act No 84 of 1996
Allows public schools to appoint an Accounting Officer to report on financial records where an audit is not legally required.
Trust Property Control Act, 1988
Requires an Accounting Officer report on trust financials where the trust deed explicitly provides for such an engagement.
Financial Advisory and Intermediary Services Act (FAIS Act), 2002
Regulatory guidance has allowed smaller FSPs to submit AO reports confirming record-keeping and financial accountability as an alternative to audits.
National Credit Act, 34 of 2005
Requires credit providers to report their financial position to the National Credit Regulator (NCR). AO reports may be accepted to confirm that proper records are kept.
Sets out governance and reporting obligations based on size and structure. Small co-operatives may use AO reports where audits are not required.
Entities that raise public funds must submit financial statements. AO reports may be accepted as evidence of proper financial management for smaller entities.
Beneficiaries of lottery funding must submit financial statements to the National Lotteries Commission. AO factual findings reports are often accepted for smaller grants.
Community broadcasters may be required to report on licence-related financial conditions. In practice, AO reports are accepted by some regulators where full audits are not required.
Construction Industry Development Board (CIDB) Act, 2000
While not mandated, smaller contractors often use AO reports to verify financial records for CIDB registration or grading when audits are not required.
6. How to Apply
Steps to offer or use AO services:
Determine if your entity (e.g. CC, trust, NPO) is required by law to appoint an AO.
Engage a CBAP who is recognised as an AO under Section 60.
Sign an engagement letter defining scope and deliverables.
Accountant applies ISRS 4400 procedures and issues report.
Submit AO report to regulators, boards, or funders as required.
7. Common Mistakes to Avoid
Avoid pitfalls that increase risk and non-compliance:
Not signing an engagement letter → this will increase potential liability.
Using unqualified practitioners → only CIBA CBAPs are recognised as AOs.
Ignoring statutes outside the Close Corporations Act.
Failing to align with ISRS 4400 standards.
8. Related Resources
Visit the cpd.myciba.org website for a list of CPD offerings.
Read the articles on various topics and get unverifiable CPD points on Accounting Weekly
9. Need Help?
Any assistance required for technical enquiries, membership related queries, access to the system you need to log into your member profile and: