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Financial Reporting Costs Consultation – Market Feedback and Proposed
GEN – General – JSE Limited
Financial Reporting Costs Consultation – Market Feedback and Proposed
Amendments to the JSE Listings Requirements
In November 2025, the JSE published a Consultation Paper on financial reporting costs following feedback
received through a market survey conducted in June 2023. The survey identified financial reporting and
audit-related costs as among the most significant costs associated with maintaining a listing on the JSE.
The consultation formed part of the JSE's broader programme of reforms aimed at ensuring that South
Africa's capital markets remain competitive, attractive and appropriately regulated. The JSE has already
undertaken several significant initiatives to reduce unnecessary complexity and compliance costs for
listed companies, while maintaining robust standards of investor protection and market integrity. These
initiatives include the introduction of market segmentation, the comprehensive Listings Requirements
Simplification Project and the removal of the auditor accreditation model, which broadened the pool of
firms available to audit listed companies and sought to enhance issuer choice in the audit market.
Together, these reforms are intended to establish a more proportionate and fit-for-purpose regulatory
framework that recognises the differing characteristics of issuers, removes duplication where possible
and supports capital formation, without compromising the transparency and governance standards
expected of listed companies.
The JSE received a significant number of submissions from a broad range of stakeholders, including
institutional investors, analysts, sponsors, issuers, audit firms and regulatory bodies. The JSE appreciates
the time and effort invested by all respondents and has carefully considered the views expressed.
A consistent theme emerging from the consultation was the need to balance efforts aimed at reducing
regulatory costs and complexity with the continued provision of decision-useful information to investors
and the preservation of market confidence. Stakeholders generally supported targeted measures to
reduce administrative burden where appropriate, provided such measures do not compromise
transparency, governance standards or investor protection.
Having considered the feedback received, the JSE proposes a limited number of targeted amendments to
the JSE Listings Requirements (the "Requirements"). In several areas, stakeholders supported retaining
the current regulatory framework.
Trading statements
There was overwhelming support for the continued use of trading statements. Investors emphasised their
importance as a transparent and structured mechanism for providing earnings-related information to the
market. Issuers and sponsors similarly indicated that the trading statement framework is generally more
practical and certain to apply than a principles-based price-sensitive information regime.
JSE position
The JSE considers trading statements to remain an important component of the disclosure framework and
will therefore retain the existing requirements. The JSE will not proceed with previously contemplated
changes to trading statement thresholds, wording requirements or net asset value-based triggers.
Proposed amendment
Stakeholders raised concerns that the current drafting may inadvertently discourage issuers from
providing updated guidance to the market. Accordingly, the JSE proposes a targeted amendment to
encourage more timely market updates once an issuer has provided guidance, thereby supporting
transparency without altering the underlying trading statement framework.
Non-IFRS measures
Feedback was consistently supportive of deferring changes to the regulation of non-IFRS measures.
Respondents noted that introducing amendments before the implementation of IFRS 18 could result in
duplication or inconsistency, particularly given the expected enhancements to disclosures relating to
management-defined performance measures.
JSE position
Having considered the feedback received, the JSE will not proceed with amendments at this stage. The JSE
will reassess the framework following the implementation and market adoption of IFRS 18 and currently
expects to revisit the matter in 2028.
Headline earnings per share
An overwhelming majority of respondents supported the continued use of headline earnings per share
("HEPS"). While HEPS remains a South African reporting metric, commentators highlighted its value in
facilitating consistency, comparability and valuation analysis across listed companies.
JSE position
HEPS continues to provide useful information to investors and other market participants, therefore the JSE
will retain the existing obligation for both primary and secondary listed issuers to disclose HEPS.
Financial directors
Stakeholders strongly supported retaining the existing governance framework requiring issuers to appoint
an executive financial director, while preserving the JSE's ability to grant a variation in appropriate
circumstances.
JSE position
The JSE will retain the current requirement and does not propose any change to the underlying governance
principle.
Proposed amendment
Respondents highlighted the administrative burden associated with obtaining JSE approval in
circumstances involving temporary vacancies. The JSE therefore proposes a targeted amendment to
permit the audit committee to assume oversight responsibility during a temporary vacancy, without
requiring approval from the JSE, provided the vacancy is filled within a prescribed period.
Board committees
The consultation sought views on whether amendments should be made to the requirements relating to
the establishment and composition of Social and Ethics Committees, Remuneration Committees and
Audit Committees.
Feedback did not identify a clear basis for reducing requirements in this area. In particular, there was
strong support for maintaining the current requirements relating to the role and responsibilities of the Audit
Committee.
JSE position
The JSE considers these governance structures to remain important mechanisms for oversight and
accountability and will therefore not propose any amendments to the existing requirements.
Pro forma financial information
The consultation sought views on whether the current approach applicable to General Segment issuers,
which permits narrative disclosure in certain circumstances rather than detailed pro forma financial
information, should be extended to Prime Segment issuers. Responses did not indicate a clear consensus
in support of the proposal.
JSE position
The JSE will not proceed with extending the General Segment approach to Prime Segment issuers.
Proposed amendment
The JSE is, however, proposing a targeted amendment to clarify circumstances in which equivalent
disclosures have been prescribed by legislation or the requirements of another recognised exchange, with
the objective of reducing duplication while maintaining appropriate disclosure standards.
Restatements
Details regarding restatements are provided to the market through SENS and in the results. The
consultation sought views on changes to the additional administrative restatement notification sent to the
JSE. Respondents provided useful suggestions.
JSE position
The JSE has decided to proceed with the suggestions it received,
Proposed amendment
The JSE is proposing changes to practice note 3/2017 in order to simplify the administrative process
relating to restatement notifications provided to the JSE without diluting the information provided directly
to the market.
General simplifications
Stakeholders strongly supported three smaller simplification changes for items which lacked relevance.
JSE position
The JSE has decided to proceed with the changes.
Proposed amendments
The JSE will propose amendments to: remove disclosure of accounting policy choice for goodwill (as there
is no choice); duplicating disclosures relating to auditor changes already addressed through SENS; and
auditor confirmation of the achievement of profit warranties, except in the case of related party
transactions.
Other suggestions
The consultation process also generated a number of additional suggestions aimed at reducing
compliance costs and administrative burden for listed companies.
JSE position
While the JSE carefully considered these suggestions, stakeholders generally did not demonstrate a clear
consensus in favour of material changes to the existing framework. Having considered the additional
feedback received, other than below, the JSE does not propose any further amendments arising from these
suggestions at this stage.
Proposed amendment
Based on the suggestions made, the JSE proposes a targeted amendment to permit the distribution of the
separate Company financial statements through a web link, or secure electronic access rather than
requiring these to be included in the annual report.
The proposed amendment is intended to provide flexibility in presentation and a reduction in formatting
and production costs, freeing issuers to focus their efforts on the Group or Consolidated annual financial
statements.
Next steps
Based on the above, the proposed amendments to the Requirements for public comments are available
at https://www.jse.co.za/regulation/companies-issuer-regulation under announcements regarding
Listings Requirement – July 2026. The JSE invites comments on the proposed amendments by close of
business on 11 August 2026, and comments can be sent to consultation@jse.co.za.
The JSE thanks all stakeholders who participated in the consultation process and contributed to the
development of a balanced and proportionate regulatory framework for listed companies.
10 July 2026
Date: 10-07-2026 11:04:00
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