NCR Call for Comments: Review of the Industry Codes of Conduct

Dear Members,

Many of you will have received NCR Circular 04 of 2026, inviting industry stakeholders to submit written comments on the review of the Debt Counsellors’ Code of Conduct, the Credit Industry Code of Conduct, as well as the development of a Code of Conduct for Payment Distribution Agencies (PDAs).

We appreciate that the timing of this circular has raised questions within the industry, particularly given the many operational challenges debt counsellors continue to experience on a daily basis.

By way of background, the review of the Codes of Conduct is not a new initiative. Over the past year, DCASA has actively participated in the Credit Industry Forum (CIF) Task Team, where these documents formed part of broader discussions regarding the debt review process. During those engagements, the sub committee submitted comments indicating that, before the Codes could be reintroduced as part of the Task Team Agreement (TTA), they required further revision to ensure they remain relevant, practical and reflective of the current operating environment.

A Code of Conduct serves an important purpose. It establishes common principles, promotes ethical conduct, encourages cooperation between stakeholders and supports consistent implementation of the National Credit Act. It is intended to complement the legislative framework by promoting best practice and strengthening relationships between industry participants.

However, we also understand the concerns being expressed by many members. A Code of Conduct, regardless of how well drafted, cannot by itself resolve operational challenges if the underlying processes remain inefficient or outdated.

Over the past few years, our industry has evolved significantly. We have seen:

• Increasing operational inefficiencies and process delays;
• Challenges with existing debt review processes not keeping pace with the evolution of the industry;
• Growing pressure on relationships between industry stakeholders;
• The emergence of fraudulent and unethical practices affecting both consumers and registrants;
• Limited industry growth despite increasing consumer demand for debt intervention; and
• The need for more practical, collaborative and future-focused solutions.

These are real issues that require honest discussion and meaningful reform alongside any review of the Codes of Conduct.

Please be assured that DCASA continues to engage with the NCR, Credit Industry Forum, credit providers and other stakeholders on many of these matters. While progress may not always be as quick as we would all like, these conversations are ongoing, and DCASA remains committed to advocating for practical improvements that will strengthen the debt review industry.

DCASA will be preparing and submitting a comprehensive submission on behalf of the Association.

However, we would also encourage members to make their own independent submissions to the NCR. Your day-to-day operational experience provides valuable insight into the practical challenges faced by debt counsellors and will assist the NCR in ensuring that any revised Codes are both meaningful and workable.

The NCR has specifically encouraged registrants to engage through their industry associations, while also confirming that individual submissions remain welcome.

Should you wish to submit comments directly, these can be emailed to COC@ncr.org.za by 12 August 2026.

Download the NCR documents :

Circular 04 of 2026-Call for comments

Annexure A-DCs Code of Conduct

Annexure B-CPs Code of Conduct

We also welcome members to forward any comments or suggestions to DCASA for consideration as part of our collective submission.

Kind regards,