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Get Compliant from Anywhere, Easy and Fast!

0800 007 269 (Toll Free)
Get Compliant from Anywhere, Easy and Fast!

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  • Business Compliance

Top 7 Mistakes Companies Make When Submitting Beneficial Ownership Registers – and How to Avoid Them

When South Africa’s Companies and Intellectual Property Commission (CIPC) rolled out its beneficial ownership (BO) reporting requirements in April 2023, many business owners assumed it was just another administrative formality. But failing to submit a compliant beneficial ownership register (or BO CIPC submission) can now block your annual return, trigger penalties, and even expose directors to liability.

Sonja Du Plessis Explains:

As Sonja du Plessis, our CIPC Administrator at Company Partners with more than 10 years’ experience, explains, “Since the CIPC introduced mandatory beneficial ownership submissions, we’ve seen the same avoidable mistakes over and over again. Most of them come down to misunderstanding what the register really requires and when updates are due.”

In this article, we unpack the top 7 mistakes companies make when submitting their beneficial ownership details – along with practical examples and expert tips from Sonja and our compliance team at Company Partners.

In the past 3 months, Company Partners has assisted 275 business owners with the Beneficial Ownership Registers.

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Avoid Beneficial Ownership Mistakes That Block Compliance

Misunderstanding the Concept of Beneficial Ownership

The first and most fundamental error is failing to grasp what beneficial ownership actually means.

Many entrepreneurs think, “Our directors and shareholders are the same people, so we’re fine.” But the CIPC defines a beneficial owner as any natural person who ultimately owns or controls a company, directly or indirectly, or who benefits from its assets or income.

That includes:

  • Individuals who hold 5% or more of shares through another company or trust
  • People with voting control or the ability to appoint directors
  • Ultimate decision-makers who may not appear in official share registers

Sonja’s Insight:

“We often see holding companies or family trusts listed as shareholders without identifying the natural person behind them. The CIPC wants to know who the real human being is—who ultimately controls or benefits from the entity.”

What does this mean practically? A construction firm lists “XYZ Holdings (Pty) Ltd” as its 60% shareholder. The beneficial owner, however, is Mr. Naidoo, who owns XYZ Holdings through another trust. Unless Mr. Naidoo is disclosed as the beneficial owner, the submission is incomplete.

expert tip

Map your ownership chain all the way to the natural person level. Use a visual organogram or beneficial ownership register template to trace control through trusts or intermediaries.

Selecting the Wrong Company Classification

Every company filing with the CIPC must determine whether it’s an affected or non-affected company. Getting this wrong can derail the entire submission.

An affected company (like public, state-owned, or one controlled by a regulated entity) must maintain a beneficial interest register, while a non-affected company must lodge a beneficial ownership register disclosing any natural person who owns or controls 5% or more.

Sonja Warns:

“We often see companies select the wrong category on the e-Services portal. That mistake changes what forms must be submitted and can lead to rejections or incomplete records.”

For example; a private company partially owned by a listed entity misclassifies itself as non-affected. When CIPC cross-references shareholding data, the filing is flagged as inconsistent, delaying its annual return.

expert tip

If you’re unsure which classification applies, get advice before filing. Company Partners reviews your shareholding and entity type to confirm whether your business qualifies as affected or not.

Submitting Incomplete or Incorrect Owner Information

Another common pitfall is incomplete or inconsistent data in the beneficial ownership register.

Typical errors include:

  • Misspelled names or incorrect ID/passport numbers
  • Missing residential addresses or dates of birth
  • Out-of-date passport copies for foreign owners
  • Not providing the latest SA id that was issued/applied for at Home Affairs
  • Non-certified documents or blurred uploads


These might look minor, but CIPC systems automatically reject mismatched data.

Sonja Explains:

“Every field matters. If the ID number or nationality doesn’t match the uploaded document, the filing fails validation. We’ve seen submissions bounce back simply because the address was written as ‘SA’ instead of ‘South Africa’.”

So, say a director uploads an expired passport for a UK beneficial owner. The CIPC flags the record as invalid, halting the annual return until corrected.

expert tip

Double-check every data point. Use certified copies (not older than three months), confirm spelling and formatting, and ensure all details match the official ID.

Missing the Submission or Update Deadlines

Timing is where even diligent companies slip up.

Since 2023, every company registered with CIPC must submit its beneficial ownership information within 10 business days of incorporation, or by its next annual return if older.

If ownership changes, you must update the register within 10 business days of the change.

Sonja Emphasises:

“Late submissions now block annual returns entirely. That means you can’t stay compliant, can’t apply for tenders, and risk deregistration.”

Let’s look at what this means. A startup transfers shares to a new investor in March 2025 but only updates its beneficial ownership register in May. When filing the annual return, CIPC rejects it until the BO update is complete, causing delays with funding applications.

expert tip

Create automatic compliance reminders for both your Annual Return and any ownership change. Company Partners’ dashboard alerts you ahead of key dates so nothing slips through the cracks.

Forgetting the Filer’s Mandate

Many companies outsource filings to accountants or consultants but forget the mandate letter required by CIPC.

Without a signed authorisation from the company, the filing is technically invalid.

Sonja Explains:

“The CIPC must see proof that the person uploading the data is authorised to do so. A missing mandate can delay processing for weeks;” Sonja explains.

Let’s look at an example. A financial administrator uploads the BO register on behalf of the directors but neglects to attach the mandate. CIPC queries the submission and requires re-filing with proper authorisation.

expert tip

Always prepare a simple board resolution, signed by all the Directors or mandate letter naming your authorised filer. Keep it on record for future submissions or audits.

Uploading the Wrong Documents or File Formats

The CIPC system accepts only certain file types and supporting evidence. Submitting non-compliant files is a silent killer of otherwise correct submissions.

Typical problems include:

  • Uploading photographs of IDs instead of scanned PDFs
  • Forgetting to attach the securities register or ownership chart
  • Uploading non-certified IDs
  • Exceeding file-size limits or using corrupted files

Sonja Adds:

“Our support desk often receives frustrated calls from clients whose submissions keep failing without clear reasons. Nine times out of ten, the culprit is a document issue.”

For example, a company uploads a 15 MB JPEG of a passport instead of a compressed PDF under 2 MB. The portal rejects the file, forcing resubmission.

expert tip

Scan documents clearly, save them as PDFs, and label files consistently, e.g., “BO Register_CompanyName_2025.pdf”. Use the Company Partners’ upload checklist to ensure every supporting document is compliant before filing.

Treating Beneficial Ownership as a One-Time Task

Perhaps the most costly mistake is treating BO filing as a once-off exercise.

Beneficial Ownership changes whenever:

  • Shares are sold or transferred
  • Directors or trustees change
  • Voting or control structures shift
  • Any other changes in the shareholding structure


Ignoring these updates can invalidate your previous submission.

Sonja Concludes:

“Your beneficial ownership register should evolve with your business. It’s not a document to file and forget; it’s a living record,” Sonja concludes.

Let’s say a family business brings in a new silent partner holding 10% through a trust. The owners neglect to update their register. When they later bid on a government tender, the Central Supplier Database flags them as non-compliant.

expert tip

Integrate BO updates into your internal governance routine, just like accounting or tax. Review ownership data quarterly, or immediately after share or control changes.

Real-World Consequences of BO Errors

Mistakes in BO submissions don’t just waste time, they carry legal and financial risk:

  1. Blocked Annual Returns: You can’t file returns or generate compliance certificates until BO records are correct.
  2. Administrative fines and compliance notices from CIPC.
  3. Potential deregistration for repeated non-compliance.
  4. Director liability under the Companies Act for false or misleading declarations.
  5. Loss of credibility with banks, funders, and tender authorities who now cross-check BO compliance.


For example; a transport company failed to update its beneficial ownership before submitting a tender on the Central Supplier Database (CSD). The system flagged “non-compliant with CIPC BO requirements,” costing them a multimillion-rand contract.

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Practical Preparation Checklist

Before submitting or updating your beneficial ownership register, ensure the following:

Step Action Why it Matters
1 Confirm whether you’re an affected or non-affected company Determines which register applies
2 Identify all natural persons with 5% + ownership or control Prevents under-disclosure
3 Gather and verify certified IDs/passports Required by CIPC
4 Prepare a signed mandate letter Authorises your filer
5 Update your securities or share register Must align with BO data
6 Upload clear, correctly named PDFs Avoids rejections
7 Schedule ongoing reviews Keeps compliance current

Expert Insights: Building a Culture of Transparency

Beyond regulatory compliance, maintaining an accurate beneficial ownership register signals that your business values integrity and transparency, qualities increasingly demanded by banks, investors, and government clients.

Sonja Reflects:

“Beneficial ownership regulations are not meant to punish companies; they’re designed to prevent financial crime and improve corporate transparency. When businesses embrace that, compliance becomes part of good governance, not a burden.”

Sonja Adds:

She adds that Company Partners’ goal is to educate and support entrepreneurs. “Our clients range from start-ups to large corporates. Once they understand the process, most find it surprisingly simple, especially when guided through each step.”

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From certified IDs to correct file formats, our team carefully handles every important detail so your submission never gets rejected.
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How Company Partners Can Help

Complying with CIPC’s beneficial ownership requirements doesn’t have to be confusing. Company Partners assists hundreds of South African businesses every month with full-service BO solutions:

  • Expert Review: We assess your ownership structure and confirm whether your company is affected or non-affected.
  • Custom Templates: Get a compliant beneficial ownership register template and form checklist tailored to your business.
  • Document Preparation: We verify IDs, create mandates, and compile supporting files in the correct format.
  • *Direct Submission: Our team files directly with CIPC and troubleshoots any rejections.
  • Automatic Alerts: Receive reminders for annual or ownership-change updates.
  • Ongoing Compliance Maintenance: We update your register whenever your shareholding or control changes.


Visit our Beneficial Ownership page to start your filing today or learn more about:

Final Thoughts

Submitting your beneficial ownership register correctly the first time saves you hours of frustration and potential penalties later. Understanding who qualifies as a beneficial owner, keeping documentation accurate, and meeting CIPC deadlines will ensure your company stays compliant and trusted.

Sonja Concludes:

“Transparency is no longer optional. It’s part of doing legitimate business in South Africa. The beneficial ownership register is the CIPC’s way of ensuring that companies know, and show, who really holds the reins.”

Don’t wait for a rejection notice or blocked annual return. Contact us today and let Company Partners help you file your BO CIPC submission correctly.

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