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South Africa

Beneficial Ownership Transparency (ZA0026)



Action Plan: South Africa Action Plan 2020-2022

Action Plan Cycle: 2020



Lead Institution: Department of Public Service and Administration (DPSA) with the Technical Support of Financial Intelligence Centre (FIC)

Support Institution(s):

Policy Areas

Anti Corruption and Integrity, Beneficial Ownership, Private Sector

IRM Review

IRM Report: South Africa Results Report 2020-2022, South Africa Action Plan Review 2020-2022

Early Results: No early results to report yet

Design i

Verifiable: No

Relevant to OGP Values: Yes

Ambition (see definition): No Data

Implementation i



What is the public problem that the commitment will address? The South Africa Open Government Partnership is developing its 4 th National Action Plan for the 2020-2022 cycle. The SA OGP process had its first beneficial ownership transparency commitment in the 3rd OGP National Action. Several milestones have been achieved in response to the commitment. BOT remains crucial for South Africa’s open governance, and stemming the tide against corruption, moneylaundering and illicit financial flows.

What is the commitment? 1. To review the progress made in the 3rd Country Action Plan and align it with the priorities of the 6th Administration, especially the work done under the Security Cluster. 2. To propose the course of action on carrying forward with the BOT commitment under the OGP auspices given the sixth Administration priorities.

IRM Midterm Status Summary

Action Plan Review

3. Beneficial Ownership Transparency

• Verifiable: No                                                    

• Does it have an open government lens? Yes

• Potential for results: Unclear

• Clustered: No

IRM End of Term Status Summary

Results Report

Commitment 3. Beneficial Ownership Transparency

Verifiable: No

Does it have an open government lens? Yes

Potential for results: Unclear

Completion: Not started

Did it open government? No early results to report yet

This commitment aimed to review the implementation progress of the beneficial ownership transparency commitment in the previous action plan and to propose a course of action. [10] The commitment text did not include specific milestones. Regardless, the IRM researcher did not find evidence of meetings or task forces to review progress made under the previous commitment. Nor did they find evidence of a report or other document on the strategy to advance the reform. Therefore, the researcher determined this commitment had not been started.

During the previous action plan, South Africa committed to implement the G20 high-level principles on beneficial ownership transparency, set up an Inter-Departmental Committee to monitor the implementation, and develop an implementation plan. [11] There is evidence that the Inter-Departmental Committee was established. [12] South Africa has also sought to amend the Financial Intelligence Centre Act, 2001; the Companies Act; The Trust Act; and the Nonprofit Organisation Act in an effort to comply with the G20 high-level principles on Beneficial Ownership Transparency and Financial Action Task Force requirements.

However, the current iteration of South Africa’s OGP commitment to beneficial ownership transparency did not outline specific activities or a policy objective it sought to advance. Therefore, it is not possible to attribute these efforts to the OGP commitment. As a result, this commitment was not found to have opened government.

[10] ‘South Africa Action Plan Review 2020–2022’, IRM, OGP, 26 July 2021,
[11] ‘The 3rd South African Open Government Partnership Country Action Plan, 2015–2017’, OGP,
[12] ‘Implementing Beneficial Ownership Transparency for anti-corruption and good governance in South Africa’, United Nations Office on Drugs and Crime, 2, 23 March 2021,


Open Government Partnership