DO YOU REALLY NEED TO SUBMIT A PAIA ANNUAL REPORT? YES – HERE'S WHY

Compliance Hub Consulting
Jun 27
2 min read

At Compliance Hub Consulting, we often get asked: "Are we exempt from submitting a PAIA Annual Report?" The short answer? No. Almost every entity classified as a public or private body is required to submit an annual PAIA report – including a nil report where applicable.

What Is the PAIA Annual Report?

The Promotion of Access to Information Act (PAIA) ensures transparency and accountability by obligating organisations to report annually on access to information requests. This report is submitted to the Information Regulator and forms part of South Africa’s drive toward open governance and corporate responsibility.

Public Bodies: No Exceptions

Public bodies have no exemption from PAIA reporting. In terms of Section 32 of PAIA, this annual report is a legal requirement. Failing to submit is a direct breach of your legislative obligations – and the Information Regulator is tightening enforcement.

Private Bodies: Still Required to Report

While Section 83(4) of PAIA states that private bodies "may" submit reports, legal interpretations confirm that this is not optional in practice. The Information Regulator, along with most legal experts, expects all private entities that fall within the definition of a "private body" to submit PAIA reports annually.

Even companies that are exempt from compiling a PAIA manual (based on size, sector, or turnover thresholds) are not exempt from reporting if:

They received any access to information requests, or
They wish to confirm no such requests were received via a nil report.

What Happens If You Don’t Report?

Non-compliance may:

Raise red flags during audits or due diligence,
Undermine your corporate governance credentials,
Lead to potential enforcement action from the Information Regulator.

Compliance Hub’s Advice: Submit Every Year

Whether you had 0 or 100 access to information requests – your duty remains. At Compliance Hub Consulting, we guide our clients through the reporting process, ensuring that their PAIA reports are submitted accurately, on time, and in full compliance with legislative expectations.

Need help filing your PAIA report before 30 June 2025?