Just Share welcomes the operationalisation of the long-awaited sections 30A and 30B of the Companies Amendment Act as a step in the right direction in addressing the lack of pay transparency at JSE-listed companies. The Act introduces significant remuneration disclosure and shareholder accountability requirements for public and state-owned companies in South Africa.
On 2 April 2026, Just Share submitted a Promotion of Access to Information Act (PAIA) request seeking clarity on why sections 30A and 30B of the Companies Act remained unoperational (1 year and 4 months) after it was passed into law. Just Share’s PAIA request followed several prior communications from the Department of Trade, Industry and Competition (the dtic) indicating that these provisions would be operationalised during 2025.
This was especially notable given that the Companies Amendment Act 16 of 2024 had already been signed into law and partially commenced in December 2024, following a lengthy reform process in which Just Share has actively participated since 2018 through written submissions, parliamentary engagements and collaborations with civil society organisations. During this process, Just Share also co-submitted comments and participated in advocacy engagements alongside the Association of Black Securities and Investment Professionals (ABSIP) and Aeon Investment Management.
On 30 April 2026, Just Share received a response from the dtic requesting an extension until 2 June 2026 to process the PAIA request, stating that it was “not yet possible to provide a substantive response” at the time. While we still look forward to receiving an outcome on the PAIA request, Just Share is pleased that the 22 May 2025 presidential proclamation has brought these key sections into operation.
Until now, wage gap disclosures in South Africa have largely remained voluntary and inconsistently disclosed by JSE-listed companies, despite growing investor and public interest in fair pay, inequality and executive remuneration practices.
With the implementation of sections 30A and 30B, public and state-owned companies are now required to table both a remuneration policy and a remuneration report at their annual general meetings. The disclosures must include:
- the total remuneration received by each director and prescribed officer;
- the total remuneration of the highest- and lowest-paid employees;
- the average and median total remuneration of all employees; and
- the remuneration gap, expressed as the ratio between the total remuneration of the top 5% highest-paid employees and that of the bottom 5% paid employees.
The remuneration policy must be approved by a binding shareholder vote at least once every three years, while the remuneration report must be approved annually. If the report is rejected by shareholders, the remuneration committee will be obliged, at the next AGM, to explain how it has addressed shareholders’ concerns. If the remuneration report is rejected for a second consecutive year, the non-executive directors serving on the remuneration committee will be barred from serving on that committee for two years.
These reforms materially strengthen shareholder oversight over remuneration practices and create a more direct line of accountability between boards and investors. Historically, remuneration votes in South Africa were largely advisory and often lacked meaningful consequences when shareholders expressed dissatisfaction. The new framework increases the governance risks for boards that fail to adequately justify remuneration outcomes, particularly where excessive executive pay coexists with low wages, widening inequality, or poor transformation outcomes.
For shareholders, particularly responsible and long-term institutional investors, the new disclosure regime creates a significantly stronger evidentiary basis for assessing whether remuneration structures align with principles of fair pay, and long-term value creation. Investors will now be better positioned to interrogate whether remuneration outcomes reflect genuine shared value creation across the workforce, or whether value continues to accrue disproportionately to senior executives and top earners. The success of the new legal framework will depend on whether investors choose to use their power as owners to demand more equitable and transparent remuneration practices.
Image for illustrative purposes only, courtesy of GovernmentZA, Flickr
