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Every South African Business Has Been Legally Required to Have a PAIA Manual Since 2022

The Promotion of Access to Information Act requires every private body, regardless of size, to compile a manual explaining what records it holds and how to request access — the deadline passed on 31 December 2021, and it's a criminal offence under Section 90 of PAIA not to have one at all.

Many small and medium South African businesses remain unaware they're legally required to have this document. Since amendments linked to POPIA, the manual must also incorporate how the business processes personal information — meaning the two laws' compliance obligations are now intertwined rather than separate.

Source: Promotion of Access to Information Act 2 of 2000

Frequently Asked Questions

Is every business, regardless of size, required to have a PAIA manual?

Yes — since 1 January 2022, there is no general size-based exemption; certain narrow exemptions exist only where specifically gazetted.

What's the penalty for not having a PAIA manual?

Not having a required manual is a criminal offence under Section 90 of PAIA, separate from any penalties tied to POPIA non-compliance.

Does a PAIA manual overlap with POPIA obligations?

Yes — since amendments introduced by POPIA, a business's PAIA manual must also include details of how it processes personal information.

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