South Africa’s new CIS conduct standard, FSCA Conduct Standard 3 of 2025 (CIS), has applied to managers of collective investment schemes since 15 August 2026. Alongside its governance requirements, it sets firm rules on prospectuses, on product governance over disclosure documents and on how quickly investors must hear about material events. Most of the commentary so far has understandably focused on governance and control functions, but these document rules from the Financial Sector Conduct Authority land squarely on the people who produce fund documents.
What is the new conduct standard for collective investment schemes?
The FSCA made Conduct Standard 3 of 2025 under section 106(1) of the Financial Sector Regulation Act, 2017. It was published on 14 August 2025 and, under its own commencement clause, came into effect 12 months later, on 15 August 2026.
It applies to all CIS managers except managers of schemes in participation bonds. It can be applied proportionately to the nature, size, scale and complexity of the manager, unless a specific requirement doesn’t allow for that. The standard runs to nine chapters which, alongside definitions and commencement, cover governance and control functions, conflicts of interest, portfolio development, prospectuses, custody, material event notifications, and a set of miscellaneous rules on trade execution and related-party transactions.
What changes for documents?
The starting point is that every portfolio needs a prospectus. A manager must have one for all its approved schemes and portfolios, and it must be given to every new investor before the investment transaction is concluded, be available at the manager’s South African office or on its website, and be amended so that it always reflects approved changes.
The standard is also explicit that the prospectus can’t replace the Minimum Disclosure Document (MDD). It should normally hold information of a more static nature and may not include any portfolio performance or returns data, so performance stays where it already lives, in the MDD and in marketing material governed by Board Notice 92 of 2014.
As for content, the prospectus must give an overall, transparent view of the scheme and all its approved portfolios, disclose relevant material matters, including anything that may need an investor ballot, and indicate which reports investors are entitled to and how often. The FSCA can set the manner and form, and add further matters, by notice on its website.
Disclosure documents now go through product governance as well. Before a new portfolio, or a material amendment to an existing one, goes to the FSCA for approval or to market, a senior manager or committee must approve it in writing and confirm that the portfolio, its distribution methods and its disclosure documents meet the standard’s design tests. After launch, the manager has to keep reviewing whether those documents remain appropriate for the investors the portfolio targets.
Distributors are to get the same information too, because managers must provide all the information, disclosures and reports they give investors, other than investment statements, to the financial services providers who deal with those investors.
How quickly must investors hear about material events?
The standard’s annexure sets a notification period for each listed event, and the manager must notify affected investors in writing. A few of those periods will shape the calendar:
- Fee changes need three months’ notice before an increase, or before a change in method that could raise or introduce a charge.
- Changes to investment objective or policy must be notified within 10 business days of the deed amendment, with dissenting investors offered a switch or redemption at no extra cost.
- Changes to the distribution or accounting period, or the financial year end, need 30 business days’ notice.
- Changes to valuation or cut-off times need one month’s notice.
- Investment manager changes must be notified within 14 business days.
- Material pricing errors must be notified within five business days of identifying the error, explaining its effect and how it’s being fixed.
- Suspensions of repurchase or dealing must be notified as soon as reasonably practical, and no later than one business day.
Beyond the list, managers must judge case by case whether any other event is material and, if it is, tell investors in a timely way.
What it means in practice
Some of this formalises what well-run managers already do, but it’s now set out in a conduct standard with dates attached. Fee changes need a three-month runway built into the product calendar, and pricing errors need a process that can produce an investor notice within five business days, explaining the impact rather than simply recording a correction. Any prospectus that carries performance numbers will need them taken out.
The product governance rules matter just as much, because written sign-off that disclosure documents fit the target market, followed by ongoing review, means someone has to be able to show which version of a document was approved, by whom and when.
The timeline
- 14 August 2025: Conduct Standard 3 of 2025 is published
- 15 August 2026: the standard comes into effect
- Ongoing: fee changes, deed amendments and other listed events are notified on the standard’s timescales, and the FSCA may set the form of the prospectus by notice
What to do now
- Check every prospectus, confirming that each approved portfolio has one, that it’s on your website or available at your office, and that no performance or returns data has found its way in.
- Rebuild your event calendar by mapping each annexure event to an owner, a template notice and a deadline, starting with fee changes and pricing errors.
- Evidence your sign-offs, making sure portfolio approvals record the review of disclosure documents and that post-launch reviews are scheduled and documented.
Conduct Standard 3 is mostly a governance standard, but it reaches directly into the documents investors read, and now that it’s in force the next fee change or pricing error is likely to be the first real test of whether those processes are ready.
For us, the new standard is about keeping investor communication in step with the facts. Prospectuses, MDDs, notices and fund web pages all draw on the same portfolio data, and the standard now puts dates on when changes must reach investors. When that data and the regulatory documents it feeds are governed in one place, with approvals and versions on record, an investor notice is a controlled output rather than a scramble. If you’d like to talk it through, get in touch.
Sources: FSCA Conduct Standard 3 of 2025 (CIS): Requirements for Managers of Collective Investment Schemes (FSCA website: Supervisory Information, Standards, CIS, Conduct Standards), Board Notice 92 of 2014, Government Gazette 37895, as at 1 September 2026.
