A comparison of the South African transparency requirements for executive remuneration

Abstract

In South Africa, there is still significant interest in executive remuneration due to widening income inequality, volatile economies, and concerns about the accountability of business executives. This study examines how much the suggested changes to the Companies Act 71 of 2008, the King IV report on corporate governance (IoDSA, 2016), and the King V code on corporate governance for South Africa (IoDSA, 2025) improve transparency in executive pay. The report also examines how South Africa's changing rules for employee pay compare with those in the United Kingdom and Australia, two countries with well-established and enforceable corporate governance regimes. This study uses a qualitative research design based on Saunders' research onion. It includes a critical examination of the literature and a comparison of statutory requirements, governance rules, shareholder voting methods, and enforcement procedures. The results reveal that South Africa has built a strong conceptual framework based on fairness, internal equality, social justice, and the inclusion of all stakeholders. South Africa is becoming a leader in transparency linked to distributive justice because of legislative changes, including mandated individual wage disclosures and wage-gap reporting. King IV and King V strengthen governance requirements further by adding sustainability, ESG-linked pay measures, and additional duties for the compensation committee. The report, however, suggests that a lack of unified regulatory oversight, weak enforcement powers, and a lack of binding shareholder control mechanisms still constrain South Africa's actual effectiveness. On the other hand, the United Kingdom and Australia use uniform remuneration reports, binding votes or two-strikes regulations, and potent centralised regulators, which make them much more accountable. The analysis finds that South Africa's system for making remuneration information public is generally good, but it needs specific changes to ensure it is actually accountable and in line with best practices worldwide. Suggestions include strengthening regulations, making statutory disclosures more detailed, and implementing shareholder oversight systems that are easier to implement. Future studies should examine how wage-gap reporting affects implementation, how ESG-linked incentives evolve over time, and the role of sustainability reporting frameworks in governance.