The Financial Accountability Supplement is a short financial declaration submitted with your CIPC annual return by companies that are not required to file annual financial statements. Companies whose statements are audited generally file the statements themselves in iXBRL format instead. Which route applies to you is determined by your public interest score and whether your financial statements were audited, independently reviewed or internally compiled.
Most small owner-managed companies file the FAS. Very few of them know how the score that put them there is calculated, or how close they are to crossing into a far more expensive obligation.
The two routes
Every company submits financial information with its annual return. There are two ways to do it.
| Annual financial statements | Financial Accountability Supplement | |
|---|---|---|
| Who files it | Companies required to have audited AFS | Companies not required to file AFS |
| Format | iXBRL — a structured digital format | An online declaration with the annual return |
| Content | Full financial statements | Summary financial and company information |
| Cost to produce | Audit fees plus iXBRL tagging | Minimal beyond preparing the underlying numbers |
The FAS is not a soft option. It is a declaration to a public register, made by the company, and it should reconcile to your actual financial statements. Filing figures that do not match the accounts you gave your bank or SARS is a problem you do not want to have to explain.
What the FAS asks for
Requirements are set by CIPC and change from time to time, so confirm the current form before filing. Broadly, expect it to cover:
Turnover for the financial year
Total assets and total liabilities
The number of employees
Details of the directors
Whether the financial statements were audited, independently reviewed or internally compiled
Who prepared them, and their professional standing
The company's public interest score
You need your financial statements before you can complete it. The most common reason a business is stuck at the annual return deadline is not the CIPC form — it is that the accounts for the year in question were never finished.
The public interest score
This is the number that determines your obligations, and it is worth being able to calculate.
The score is the sum of four components, calculated for the financial year:
| Component | Points |
|---|---|
| Turnover | 1 point per R1 million, or part thereof |
| Employees | 1 point per employee, using the average for the year |
| Third-party liabilities | 1 point per R1 million, or part thereof, held at year end |
| Beneficial interest in shares | 1 point per individual with a beneficial interest |
A worked example. A company with R14.6 million turnover, 22 employees, R3.4 million of third-party liabilities and 3 shareholders:
| Calculation | Points | |
|---|---|---|
| Turnover | R14.6m, rounded up | 15 |
| Employees | Average for the year | 22 |
| Third-party liabilities | R3.4m, rounded up | 4 |
| Beneficial interest holders | 3 individuals | 3 |
| Public interest score | 44 |
A second example, showing how quickly it moves. The same company two years later at R28 million turnover, 61 employees, R9.2 million of liabilities and 4 shareholders:
| Points | |
|---|---|
| Turnover | 28 |
| Employees | 61 |
| Third-party liabilities | 10 |
| Beneficial interest holders | 4 |
| Public interest score | 103 |
It has crossed 100. That single fact changes the company's reporting obligations and its cost base, and nothing about the business felt different on the day it happened.
Note that headcount dominates the score for most SMEs. A labour-intensive business with modest turnover scores far higher than a high-margin consultancy with the same revenue. Growing your team is the fastest route across a threshold.
What the score determines
Broadly, and subject to the specific rules:
Score of 350 or more: annual financial statements must be audited.
Score of 100 to 349: an audit is required where the statements were internally compiled; an independent review where they were independently compiled by a qualified person.
Score below 100: an independent review is generally required — unless the statements were internally compiled and every shareholder is also a director, in which case neither an audit nor an independent review is required.
Separately, a company that holds assets in a fiduciary capacity for others above the prescribed amount must be audited regardless of score, and your MOI can voluntarily require an audit even where the law does not.
That last exemption is the one most owner-managed companies rely on. Two founders who are both shareholders and both directors, with statements compiled internally, need neither an audit nor a review — and file the FAS. The moment they bring in a shareholder who is not a director, the exemption falls away. That is a genuine and frequently overlooked cost of taking on a passive investor.
Where companies get this wrong
Not calculating the score at all. Most small companies have never worked it out, which means they do not know how close they are to an audit obligation that will cost multiples of what they currently pay.
Averaging employees incorrectly. It is the average over the year, not the headcount on the last day. A seasonal business that runs 40 people for four months and 12 for the rest is not a 12-employee company for this purpose.
Forgetting that shareholder loans are liabilities. Director and shareholder loan accounts are third-party liabilities and count towards the score. A company funded by its owners can score higher than it expects.
Assuming the exemption applies when it does not. "Every shareholder is also a director" means every one. One family member holding 5% who has never been a director defeats it entirely.
Filing a FAS that does not reconcile to the accounts. The figures are on a public register and should match what you have told SARS and your bank.
Not being able to file at all, because the financial statements for the year were never prepared. This is the most common practical blockage, and it is what turns a small annual return problem into an unfiled return, then a compliance notice, then deregistration. See what is your company's anniversary date.
What to do about it
Calculate your public interest score every year, as part of preparing the accounts, and write it into the file. It takes ten minutes and it tells you what your obligations are.
Project it forward. If you are at 80 and hiring 25 people next year, you will cross 100 and your reporting obligations change. Budget for it before it happens rather than discovering it in your anniversary month.
Understand the audit trigger before you take on an investor, because a non-director shareholder can remove your exemption entirely.
Get the financial statements done on time. Everything downstream — the FAS, the annual return, the tax return, the bank — depends on them existing.
Frequently asked questions
What is the Financial Accountability Supplement? A short financial declaration submitted with the CIPC annual return by companies that are not required to file annual financial statements. It covers turnover, assets, liabilities, employees, director details, how the statements were prepared and the public interest score.
Who has to file a FAS instead of financial statements? Companies not required to submit audited annual financial statements to CIPC. Companies whose statements are audited generally file the statements in iXBRL format instead. Which applies depends on your public interest score and whether the statements were audited, independently reviewed or internally compiled.
How is the public interest score calculated? Add one point per R1 million of turnover or part thereof, one point per employee based on the average for the year, one point per R1 million of third-party liabilities or part thereof at year end, and one point for each individual with a beneficial interest in the company's shares.
What public interest score requires an audit? Broadly, a score of 350 or more requires an audit. Between 100 and 349, an audit is required where statements were internally compiled and an independent review where they were independently compiled. Below 100 an independent review generally applies, unless the statements were internally compiled and every shareholder is also a director.
Do shareholder loans count towards the public interest score? Yes. Director and shareholder loan accounts are third-party liabilities and count at one point per R1 million or part thereof, which means an owner-funded company can score higher than expected.
Can I file a CIPC annual return without financial statements? You still need the underlying financial information, because the FAS requires turnover, assets, liabilities and employee numbers. In practice the most common reason a company cannot file its annual return is that the accounts for that year were never prepared.
Does taking on a new shareholder affect my audit exemption? It can. The exemption from both audit and independent review for companies scoring under 100 depends on every shareholder also being a director. A passive investor who is not a director removes it.
How are employees counted for the public interest score? On the average over the financial year, not the headcount at year end. Seasonal businesses need to average properly rather than using the closing number.
Know your score before it changes your obligations
The FAS itself takes fifteen minutes. What matters is the number behind it — and whether the business is one good hiring year away from an audit requirement nobody budgeted for.
Smartbook prepares the financial statements, calculates and tracks the public interest score, and files the FAS with the annual return in your anniversary month.
Sort out your CIPC annual returns →
Last reviewed: 28 July 2026. Written by the Smartbook team — SAIPA and SAICA accredited, SARS registered tax practitioners. Public interest score thresholds, audit and independent review requirements and the content of the FAS are governed by the Companies Act and Regulations and change from time to time — confirm current requirements at cipc.co.za and take advice on your specific position. General guidance, not advice on your circumstances.
Primary sources: CIPC · Companies Act 71 of 2008 and Companies Regulations 2011 · CIPC e-Services