Key Individual requirements in South Africa: FSCA approval, the RE1 and the registration process

The requirements to be a key individual in South Africa: FSCA approval as fit and proper, which means passing the RE1 regulatory exam, holding a recognised qualification, having at least one year of management experience, and meeting the honesty and integrity standard. Your FSP then registers the approval against its licence. Here is what each requirement involves and how the registration process works.

What is a key individual?

A key individual is the person the FSCA has approved to manage or oversee the rendering of financial services by a financial services provider. Every FSP licence needs at least one, and the KI carries personal accountability for the FSP's FAIS compliance. It is a regulator-approved role, not a job title an employer can hand out.

This page is the reference for the requirements themselves. For the career view, what the role is like and what a realistic path to approval looks like, read how to become a Key Individual. If you are unsure whether the KI exam or the representative exam applies to you, RE1 vs RE5 settles that first. And for what the role does day to day, key individual responsibilities covers the duties and the liability.

Key individual requirements

The standard is set by the FSCA's Determination of Fit and Proper Requirements (Board Notice 194 of 2017). To be approved, a key individual must satisfy each of the following.

• The RE1 regulatory exam. The RE1 is the key individual regulatory exam, and it must be passed before the FSCA will grant approval. It has 80 multiple-choice questions with a pass mark of 65%, which on an 80-question paper is exactly 52 correct answers.
• A recognised qualification. The qualification must appear on the FSCA's list of recognised qualifications for key individuals in the relevant FSP category. For a Category II, IIA or III FSP, the Determination requires the qualification to be at degree level. Check your specific qualification against the FSCA's published list before relying on it.
• Management experience. A key individual must have at least one year's experience in the management or oversight of the rendering of the financial services concerned, and that applies across Categories I, II, IIA, III and IV. The experience lapses if you have not managed or overseen those services for five consecutive years.
• Honesty, integrity and good standing. The Determination requires a clean record on dishonesty offences, and both the FSP and the key individual carry a duty to disclose anything that bears on it. Criminal findings involving dishonesty, certain civil judgments and past regulatory action all weigh against approval.
• Operational ability. The KI must genuinely have the capacity and decision-making powers to manage or oversee the FSP's financial services, not merely lend a name to the licence.
• Ongoing obligations. Approval is not the end of it. Key individuals must complete continuous professional development each CPD cycle, which runs from 1 June to 31 May, with the minimum hours (6, 12 or 18) set by how many classes of business are covered. Class of business training applies too, unless an exemption in the Determination covers you.

The key individual registration process

A key individual is not registered in isolation. Approval is granted against a specific FSP licence, and it is the FSP that applies to the FSCA. The process runs in this order.

1. The FSP confirms the appointment. The FSP decides to appoint you as a KI for specific categories and classes of business, and checks your qualification, experience and RE1 status against them.
2. You meet the competence requirements first. The Determination requires the regulatory exam to be passed before approval, so the RE1 comes before the application, not after it.
3. The FSP submits a profile change to the FSCA. Adding a key individual is a change to the FSP's licence profile, submitted through the FSCA's online portal or licensing forms. The application includes Form FSP 4D, the fitness and propriety questionnaire for key individuals, along with a certified copy of your ID and evidence of your qualification and experience.
4. The FSCA assesses fit and proper. The Authority checks the RE1 result, the qualification, the experience claimed and the honesty and integrity declarations. Incomplete applications are the most common cause of delay.
5. Approval is granted and reflected on the licence. Once approved, you appear as a key individual against the FSP's licence. Material changes after that, such as the KI leaving, must be reported to the FSCA within 15 days.

If the same person will also act as a representative, that is a separate appointment with its own requirements.

The KI exam: what the RE1 involves

The RE1 is written through Moonstone, the FSCA-appointed exam body. It has 80 multiple-choice questions, a pass mark of 65% (52 of 80 correct), and costs R1 300 VAT inclusive per attempt. It tests the FAIS regulatory framework from the key individual's side: oversight duties, the fit and proper requirements themselves, licensing, and what the Act demands of the FSP you would be accountable for.

The complete RE1 exam guide covers the format, syllabus and preparation in detail, RE1 exam dates lists the upcoming sittings, and the booking walkthrough applies to the RE1 as well as the RE5, because both run through the same Moonstone portal.

How long does it take and what does it cost?

The direct cost is the exam: R1 300 VAT inclusive per attempt. A failed attempt costs the full fee again, so the honest budget question is how many attempts you need, which what the RE5 and RE1 actually cost works through.

On timing, three clocks matter. Exam results can take up to 20 working days to be released. The FSCA does not publish a fixed turnaround for profile changes, and a complete application moves faster than one it has to query. And because the RE1 must be passed before the application can succeed, the exam date you can actually get is usually the binding constraint. Working backwards from a deadline shows how to sequence it.

Can you be a KI and a representative at the same time?

Yes, and in smaller FSPs it is the norm: the owner advises clients as a representative and oversees the business as its key individual. The two roles keep separate requirements. As a representative you need the RE5 and a place on the representative register; as a KI you need the RE1 and FSCA approval. One exam does not exempt you from the other, and RE1 vs RE5 explains how the papers differ.

If the RE1 is the requirement standing between you and approval, start by finding out where you actually stand. PassPath's free readiness check takes about 15 minutes and needs no card. It scores you against the qualifying criteria the RE1 tests and returns a topic-by-topic view of where you are strong and where you would lose marks, so you can target the gaps before paying R1 300 for a sitting.

PassPath is an independent study platform. The RE1 and RE5 are written through Moonstone; PassPath is not affiliated with Moonstone or the FSCA.