Author: Callie Strydom, Head of Commercial, BRISCH
Date: 1 August 2026
The question came up recently: Is BRISCH COFI ready?
It is a good question – and one that more financial advisers and practice owners are likely to be asking as South Africa moves closer to a new market conduct framework.
The Conduct of Financial Institutions (COFI) Bill was formally introduced in the National Assembly in April 2026. Its stated purpose is to establish a consolidated, comprehensive, and consistent framework for regulating the conduct of financial institutions. At the time of writing, COFI remains a Bill, and the legislative process is still underway.
That distinction matters.
It means that nobody should be treating COFI as though the final regulatory framework is already fully in force. It also means that claims of being definitively “COFI compliant” or “COFI ready” need to be approached carefully.
What we can do, however, is understand the direction in which regulation is moving – and consider what that direction could mean for the way advisory practices operate.
What is COFI trying to change?
South Africa’s financial sector is already subject to extensive conduct regulation. COFI is not introducing the concept of fair customer treatment for the first time.
The explanatory summary published with the Bill describes its purpose as establishing a comprehensive and consistent regulatory framework for the conduct of licensed financial institutions. The FSCA has similarly identified preparation for COFI as a major regulatory priority, including the development of the supporting conduct regulatory framework.
For advisory practices, the important point is not simply that another piece of legislation is coming. It is the continued movement towards an increasingly outcomes-focused approach to conduct regulation.
That changes the nature of the conversation.
The question becomes less about whether a particular compliance step was completed in isolation and more about whether the way the business operates consistently supports appropriate outcomes for financial customers.
What does this mean for Treating Customers Fairly?
Treating Customers Fairly (TCF) is already part of South Africa’s financial-sector conduct landscape.
The proposed framework builds on the direction South African conduct regulation has already been taking: greater consistency in conduct requirements and a stronger focus on the outcomes experienced by financial customers.
For an advisory practice, this raises an important operational question.
Can the practice demonstrate, through the way it works and the records it maintains, how it supports consistent client outcomes?
That is where the COFI conversation starts becoming relevant beyond the compliance function.
What might ‘COFI readiness’ look like in practice?
Because the Bill is still progressing through the legislative process and the supporting regulatory framework continues to be developed, it would be premature to provide a definitive checklist for COFI compliance.
But practices do not need to wait for every detail to be finalised before examining their operational foundations.
Many of the disciplines that support a well-run advisory practice today are also likely to help a business adapt to a more outcomes-focused conduct environment.
Start with client information.
- Is it accurate? Is it complete? Can the appropriate people access it when they need it? Is there clarity about which record represents the most current information?
Then consider the history of the client relationship.
- Can the practice understand what advice was provided, what communication took place, what actions followed, and where responsibility sat at different points in the process?
The same questions apply to workflows.
- Does the practice have a consistent way of completing important activities, or does the process change depending on who is doing the work?
These may sound like operational questions rather than regulatory ones. That is precisely the point.
As conduct regulation becomes increasingly focused on outcomes, the distinction between “operations” and “compliance” becomes less clear. The way work is executed inside the practice can directly influence the experience and outcomes delivered to the client.
Evidence matters
A practice may believe it delivers excellent service and treats clients fairly. But in a regulated environment, intention alone is not enough. The ability to demonstrate what happened matters too.
This does not mean that every advisory practice needs to introduce layers of additional administration in anticipation of COFI. Adding more processes simply for the sake of having more controls can create its own problems.
The better question is whether the processes already in place produce reliable evidence of how the practice operates.
- Can client information be retrieved?
- Can communication history be followed?
- Can responsibilities and handovers be understood?
- Can the practice see where an activity sits in the process?
- Can someone other than the person who originally handled a matter understand what happened?
These are valuable questions regardless of the final shape of COFI. They support continuity. They reduce reliance on memory. They make oversight easier. And they help create a clearer picture of the client journey.
So, is BRISCH COFI ready?
Our answer is deliberately measured.
What we can say is that we are actively following the development of COFI and considering what the direction of conduct regulation means for the advisory practices we support.
The operational principles at the centre of our work are already relevant to that conversation.
- Quality client data.
- A clear history of client engagement.
- Structured processes.
- Defined responsibilities.
- Reliable records.
These are not guarantees of future regulatory compliance, nor are they a substitute for appropriate compliance advice. They are, however, strong operational foundations for a business that needs to adapt as regulatory expectations evolve.
What should advisory practices be doing now?
Practice owners can use this period to look critically at the way their businesses operate today.
- Where is client information stored?
- How consistently are processes followed?
- How easy is it to reconstruct the history of a client relationship?
- Where does the business still rely heavily on individual knowledge or memory?
- Where are handovers unclear?
- And if regulatory expectations require the practice to demonstrate customer outcomes more clearly in future, how easily could it do so?
These are sensible business questions now, regardless of exactly when COFI takes effect.
Final thought
The practices best positioned for regulatory change are likely to be those that already understand how work moves through their business, maintain reliable information, create clear accountability, and can demonstrate what happened throughout the client relationship.
For BRISCH, that is where the conversation about COFI readiness begins.
Not with claiming certainty about regulation that is still evolving.
But with building strong operational foundations that make practices better equipped to adapt when change arrives.
More about the author:
Callie holds a Postgraduate Diploma in Financial Planning (CFP®) from the University of Free State and is also a Chartered Accountant (CA (SA)). He hails from Pretoria and completed his BCom Hons (Acc) at UNISA. He completed his articles with KPMG and entered the banking industry in 1989. He left to work in Malawi as CFO for 6 years, then joined Absa Corporate Bank in 1999 as Key Relations Manager for major listed groups such as Naspers, MTN and Telkom. In 2008, he moved to Cape Town and worked as Wealth Manager for Absa Private Bank and Regional Manager for Absa Insurance and Financial Advisers, overseeing various teams of advisers and gaining thorough experience in the field over the past 14 years. He is results- and detail-oriented and likes to add value whilst building solid and long-lasting relationships along the way.