It is required of senior management service (SMS) members in the Public Service to disclose their interests once a year on an electronic Disclosure system (eDisclosure).  The Minister for the Public Service and Administration, expanded this requirement to also include other categories, by issuing directives and determinations.  The aim is to introduce new categories in a staggered fashion, while expanding the eDislcosure system, so that eventually all Public Servants will be disclosing their interests.

It is required of SMS and other categories to disclose their interests so that heads of departments, the Public Service Commission (PSC) and DPSA will be able to detect and manage conflicts of interest at an early stage.

The PSC is mandated to scrutinise the submissions of declarations of interests of SMS for possible conflicts of interests.  The rest are scrutinised by heads of departments.  It is expected of departments to act against employees who are found to have conflicts of interest.

The DPSA (notably the Public Administration Ethics, Integrity and Disciplinary Technical Assistance Unit – TAU) provides technical assistance to departments throughout the process.  The disclosure rate as well as interventions and findings are presented by the PSC and DPSA to the relevant parliament portfolio committee.

In terms of Regulation 18 of the Public Service Regulations, 2016, all SMS members are required to disclose their financial interests to their relevant head of department not later than 30 April of each year.  A copy of the information on the interests of Public Servants and heads of departments are submitted electronically to the Public Service Commission by 31 May, and are simultaneously directed to the DPSA.

In terms of the March 2017 Ministerial Determination and Directive on other categories of employees below SMS to disclose their financial interests, the following categories of Public Service employees are required to disclose their financial interests:

  • Level 13 and above
  • All level 12 and level 11 officials (including those on OSD level and personal notches for level 13 and above, level 12 and level 11)
  • Ethics Officers,
  • PSC Officials,
  • Supply Chain members, and
  • Finance Unit members.

Levels 13 and 12 (as well as OSD and personal notches on these levels), Ethics Officers and PSC Officials must submit their disclosures using the eDisclosure system by 30 June, and the rest of these categories must submit by 31 July.

A Directive on the form to be used by SMS members and HODs to disclose their financial interests were issued in January 2018, requiring all SMS and the aforementioned identified categories to use the eDisclosure system for disclosures.

A Guide will be introduced in April 2021 to assist departments to utilise the eDisclosure system for conducting lifestyle audits on their employees.

Regulation 19 requires of Public Service employees to disclose the following information:

  1. a) Shares, loan accounts or any other form of equity in a registered private or public companies and other corporate entities recognised by law:

(i) The number, nature and nominal value of shares of any type in any public or private company and its name; and

(ii) other forms of equity, loan accounts, and any other financial interests owned by an individual or held in any other corporate entity and its name.

(b) Income-generating assets:

(i) A description of the income-generating asset;

(ii) the nature of the income; and

(iii) the amount or value of income received.

(c) Trusts:

(i) The name of the trust, trust reference or registration number as provided by the Master of the High Court, and the region where the trust is registered;

(ii) the purpose of the trust, and your interest or role in the trust; and

(iii) the benefits or remuneration received (these include fees charged for services rendered).

(d) Directorships and partnerships:

(i) The name, type and nature of business activity of the corporate entity or partnership; and

(ii) if applicable, the amount of any remuneration received for such directorship or partnership.

(e) Remunerated work outside the employee’s employment in her or his department:

(i) The type of work;

(ii) the name, type and nature of business activity of the employer;

(iii) the amount of the remuneration received for such work; and

(iv) proof of compliance with section 30 of the Act must be attached.

(f) Consultancies and retainerships:

(i) The nature of the consultancy or retainership of any kind;

(ii) the name, type, and nature of the business activity of the client concerned; and

(iii) the value of any benefits received for such consultancy or retainers.

(g) Sponsorships:

(i) The source and description of direct financial sponsorship or assistance;

(ii) the relationship between the sponsor and the employee;

(iii) the relationship between the sponsor and the department; and

(iv) the value of the sponsorship or assistance.

(h) Gifts and hospitality from a source, other than a family member:

(i) A description, value and source of a gift;

(ii) the relationship between the giver and the employee;

(iii) the relationship between the giver and the department; and

(iv) a description and the value of any hospitality intended as a gift in kind.

(i) Ownership and other interests in immovable property:

(i) A description and extent of the land or property;

(ii) the area in which it is situated;

(iii) the purchase price, date of purchase and the outstanding bond on the property; and

(iv) the estimated market value of the property.

(j) Vehicles:

(i) A description (make and model) of the vehicle;

(ii) the registration number of the vehicle; and

(iii) the purchase price, date of purchase and the outstanding amount owing on the vehicle.

Compliance rate

 SMS MEMBERS (submission by 30 April 2020)

Number of SMS members Number of SMS members disclosed by 30 April 2020 % Disclosed
National Departments 5505 5320 97%
National Government Components 277 264 95%
Eastern Cape 637 625 98%
Free State 366 366 100%
Gauteng Province 784 784 100%
KZN 600 595 99%
Limpopo 473 471 99,58%
Mpumalanga 302 302 100%
North West 324 320 99%
Northern Cape 248 247 99,60%
Western Cape 385 385 100%
TOTAL 9901 9679 98%

Table 1:  Summary of the compliance rate by SMS members across the public service for the 2019/20 disclosure period

  • Designated employees below SMS members
Category of designated employees  




  Number Disclosed %   Number Disclosed %   Number Disclosed %   Number Disclosed %
National Departments 10512 8935 85%   3641 2312 63%   131 118 90%   34585 21968 64%
National Components 718 488 68%   607 318 52%   8 7 88%   1255 602 48%
National Prosecuting Authority 177 162 92%   1829 1580 86%   4 4 100%   83 77 93%
Eastern Cape 1447 1036 72%   3897 752 19%   25 16 64%   4138 1969 48%
Free State 652 526 81%   1864 444 24%   12 7 58%   2043 822 40%
Gauteng Province 1662 1333 80%   8341 1955 23%   57 53 93%   3649 2305 63%
KZN 1426 1061 74%   7262 2871 40%   17 14 82%   3937 2275 58%
Limpopo 1059 823 78%   3871 1308 34%   22 19 86%   1751 1151 66%
Mpumalanga 791 705 89%   1630 1204 74%   18 18 100%   1490 1212 81%
North West 797 635 80%   1734 550 32%   29 23 79%   1678 1191 71%
Nothern Cape 472 413 88%   1012 649 64%   10 10 100%   568 525 92%
Western Cape 921 872 95%   5150 3933 76%   27 27 100%   2673 2518 94%
TOTAL 20634 16989 82%   40838 17876 44%   360 316 88%   57850 36615 63%
Total no. of other categories below SMS level 119682 71796 60%                        

Table 1:  Summary of the compliance rate by other categories of designated employees below the SMS level for the 2019/20 disclosure period