Employers who have not filed a Return of Earnings for 2025 or any earlier year must submit before 31 October 2026. After that the Compensation Commissioner may raise an assessment on an estimate of your earnings, and add a penalty of up to 10% of the final assessment.
That date is not a rumour off a call centre queue. It sits in Notice 4140 of 2026, published in Government Gazette 55347 on 8 September 2026, issued in the name of Acting Compensation Fund Commissioner Farzana Fakir.
When is a Return of Earnings due?
Section 82 of the Compensation for Occupational Injuries and Diseases Act requires an employer to submit a Return of Earnings, the CF-2A or W.As 8, before 31 March each year or as the Commissioner communicates. The notice is blunt about where that duty sits: it rests with the employer to ensure the return is submitted.
For the 2025 assessment period that window was set by Notice 3894 of 2026, Government Gazette 54524 of 15 April 2026: returns were open from 1 April to 30 June 2026. A 2025 return not filed by then is one of the outstanding returns the September notice is about.
Two powers follow if a return is not filed before 31 October 2026. Section 83(6)(a) allows an assessment raised on an earnings estimate basis. Section 83(6)(b) allows a penalty, which Notice 4140 describes as not exceeding 10% of the final assessment.
Do not read "not exceeding" as a discount. The April notice said plainly that a penalty of 10% would be charged for late submission, and section 83(6)(b) of the Act itself reads "a penalty of 10 per cent of the amount so assessed". Two notices from the same Fund word it differently. Budget for the full 10%.
An estimate is somebody else's number
The first power is the one that costs more, and it draws almost no attention.
A COIDA assessment is calculated off the earnings you declare. Declare nothing and the Fund may work from an estimate instead, which means the figure your firm is billed on stops being a number you can defend with a payroll report. Correcting it afterwards is an administrative argument you begin from behind.
The notice does not say how such an estimate is built and no rate table sits in the gazette alongside it. That is a question worth putting to the Fund before the date rather than after the assessment lands.
The phrase that is in the title and nowhere else
The notice itself is headed a final reminder for the submission of 2025 and prior years outstanding Returns of Earnings, and that is all it is headed. The words "Employers blocked for Audit" appear only in the title gov.za files the document under, not once in the gazette text beneath it. Nothing in the notice comes back to explain them, and guessing at them would be worse than leaving them alone.
What the body does say is that the Department of Employment and Labour has both the right and the obligation to conduct employer compliance reviews and audits against COIDA. Take that as the signal. A department that publishes a deadline and mentions audits in the same one-page notice intends to look.
The return is the thing, the letter is the receipt
Most South African contractors think about the letter of good standing, because that is the document a client or a principal contractor asks for before anyone goes near a site. Very few think about the return, which is the filing the letter is issued off the back of.
That link is not folklore. The Department of Employment and Labour's own letter of good standing criteria are four, in order. The first two are registration with the Fund under section 80 and all returns of earnings submitted under section 82. The last two are a full assessment under section 83 and any outstanding debt settled under section 86.
Miss a return and the letter fails at the second criterion, whatever else is in order. So the failure that gets noticed is a letter being refused. The failure that actually happened was a return nobody filed months earlier.
That notice gives a turnaround of five days to issue a letter. The Fund's later guide to the letter says issuing is now automated and gives no turnaround at all, so the two documents do not agree on how long it takes. Either way the return is not the last step. It has to be assessed, and the assessment paid, before a letter can issue. Filing on 30 October does not produce a letter on 31 October.
Where it bites, and it is always the same week
The pattern is dull and it repeats. A tender closes in three weeks. The bid document asks for a valid letter of good standing. You apply, the application stalls against open returns for 2023 and 2024 that nobody in the office knew about, and the submission goes in short or does not go in at all.
Two other places it lands. A principal contractor collecting letters for everybody coming through the gate will find yours missing. A client running a maintenance panel re-checks letters on its own cycle, so a lapse surfaces in a routine sweep months after it happened.
More than seven weeks separated this notice from 31 October, and as of 16 October about two are left. That is still time to file, if not much time to clear the assessment and payment a letter needs behind each return. It is not enough time to start in the last week of October.
Arabella Infrastructure Solutions is a Johannesburg-based building maintenance and construction company that holds the compliance file for the contractors on it and watches which document lapses first when a firm goes quiet. What that check covers sits on the contractor page, and the notices we read each week are in insights.
On Monday
Log in at cfonline.labour.gov.za/OnlineSubmissions and check every assessment year, not only this one, for a return still outstanding. The Fund's guide says the letter of good standing is generated with the same username and password you use for returns, so you are already standing in the right place.
If 2025 or any earlier year is open, file it this week rather than at the end of the month. Each one is a separate return. If the log-in itself will not let you through, that is the finding rather than a technical annoyance, and the manual route given in the notice is cfcallcentre@labour.gov.za.
