November 2025

The Information Regulator (IR) has taken a tougher stance on PAIA compliance by proceeding to lay criminal charges against Information Officers and Heads of Private Bodies who fail to comply with Enforcement Notices.  During a recent media briefing, the IR confirmed that cases have been referred to SAPS. Non-compliance is now a criminal offence and can result in fines or imprisonment of up to three years.

This escalation highlights the personal risk for those appointed as Information Officers. Organisations should treat Enforcement Notices as urgent and seek legal advice promptly to avoid serious consequences.

The Legal Team has developed a PAIA Toolkit to assist our members in meeting compliance obligations and managing requests and notices. The contents of the Toolkit are listed below—simply click on the links to view the documents in each section.

PAIA TOOLKIT

INFORMATION OFFICERS: A complete guide for Information Officers:

• Guidance Note by the Information Regulator on Information Officers and Deputy Information Officers

• Information Officers - who are they?

• Role of the Information Officer

• Appointment of the Information and Deputy Information Officer

• Duties and Responsibilities of the Information Officer

• Information Officer and Deputy Information Officers tasks

PAIA MANUAL: An all-in-one PAIA manual resource:

• Guideline to Compliance with PAIA and PAJA

• PAIA Manual Template

PAIA UNPACKED: Step-by-step guides, including templates:

• PAIA Unpacked

• Step to comply with PAIA

• Refreshing your PAIA Manual

• Breakdown of PAIA

• Templates:

  • Appointment letter

  • PAIA Register

  • Acknowledgement

  • Incorrect body

  • Format or request that does not comply with PAIA

  • Extension

  • Agree to disclosure

  • Refusal

  • Personal details update form

  • Categories of PI

  • Document not found

  • Reasons to decline

SECTION 32 REPORTING: A structured template for compiling the annual Section 32 PAIA report, detailing statistics on access requests, outcomes, appeals, and compliance requirements for submission to the Information Regulator.

2021 PAIA REGULATIONS: Comprehensive regulations under the Promotion of Access to Information Act (PAIA) detailing procedures, obligations, fees, forms, and complaint mechanisms for requesting, accessing, and managing information through public and private bodies in South Africa.

PAIA PRESENTATIONS: Professional, ready-to-use presentation templates, which you can use for training and upskilling purposes.  Resources include:

• Companies Act Amendment Presentation (this amended section pertains to access to company documents, which a person has a right to apply for and which right should be read together with PAIA)

• POPIA, PAIA and PAJA Presentation