ClearComply’s analysis of 188,920 South African employers found that 72.8% are operating with an expired COIDA Letter of Good Standing. Nearly three in four employers cannot currently prove their workers are insured against workplace injuries.
But the 72.8% figure is not evenly distributed. Agriculture sits at 85.1%. Engineering sits at 60.0%. The gap between the best and worst performing industries is 25 percentage points — and it is not explained by employer conscientiousness, industry culture, or business sophistication.
It is explained by structure.
Every industry’s non-compliance rate has a structural cause. Understanding those causes tells you something important about your own risk — and why the ROE deadline is the one compliance obligation most likely to slip past you unnoticed.
The enforcement paradox: industries most associated with COIDA have the best compliance
Before examining each sector, the counterintuitive finding deserves to be stated plainly.
Construction (70.4%) and Mining (63.0%) — the two industries most associated with workplace injury and COIDA in the public mind — both sit below the national non-compliance average of 72.8%. Engineering (60.0%) is the most compliant sector in the entire dataset.
Meanwhile Financial Holdings (74.1%) — companies that manage other people’s money — outperforms no-one. Healthcare (76.2%) — employers whose workers face daily occupational injury risks — sits above the national average. Agriculture (85.1%) is the worst performer of all 15 sectors.
The explanation in one sentence: compliance follows enforcement, not awareness. Industries where non-compliance has an immediate, felt commercial consequence comply. Industries where non-compliance is invisible until a labour inspector arrives do not.
For the underlying data — the full industry-by-industry table of expiry rates — see our companion piece, COIDA Compliance in South Africa 2026: Industry-by-Industry Analysis. This article is the structural explanation that sits behind those numbers.
Agriculture — 85.1% non-compliant
Agriculture tops the table not because farmers don’t care about their workers, but because the ROE calculation is structurally harder for agricultural employers than for any other sector.
The Return of Earnings requires an employer to declare total remuneration paid to employees during the prior assessment year. For a business with a stable, fixed monthly payroll, this is a straightforward annual calculation. For an agricultural employer, it is genuinely complex.
Seasonal labour swells the headcount from eight permanent workers in winter to forty during harvest. Piece-rate workers are paid per kilogram picked rather than per hour worked. Casual workers come and go across the year. The total remuneration figure the ROE requires cannot be calculated without accurate, consolidated payroll records across all of these categories — and most small agricultural operations do not have dedicated HR or finance staff. The person responsible for the ROE is typically the same person managing the harvest, the irrigation system, and the equipment.
Add geographic distance from labour department offices, patchy digital access in many rural areas, and an industry regulator that has historically focused enforcement on labour relations rather than compensation fund compliance — and 85.1% becomes comprehensible, even if it remains a serious problem.
COIDA’s assessment tariff for agriculture reflects the occupational risk: higher-risk industries pay higher rates than lower-risk ones. Agricultural workers face genuine occupational risks — tractor accidents, chemical exposure, heat injury, equipment entanglement. A farm employer whose domestic worker, labourer, or tractor driver is injured and whose LOGS has lapsed is personally liable for the full cost of compensation and treatment.
Hospitality — 77.8% non-compliant
Hospitality’s non-compliance is driven by the combination of thin margins, seasonal workforce volatility, and high staff turnover. A restaurant owner managing a kitchen team of eight in summer and three in winter, with casual waitstaff, irregular hours, and no finance department, will consistently deprioritise an annual government submission that feels abstract until it isn’t.
The Department of Employment and Labour’s September 2024 national hospitality sweep imposed R10 million in fines on non-compliant employers in a single operation. It did not move the dial significantly on the sector’s compliance rate. This tells you something important: the enforcement visits are not yet frequent enough or consequential enough to change behaviour at scale. Hospitality employers are taking the bet that the inspector won’t arrive before the next ROE window.
That bet gets worse each year as the Department expands its inspection capacity and targets hospitality specifically as a priority sector.
Properties — 77.6% non-compliant
Property companies represent a structural compliance gap that is almost entirely explained by a misunderstanding about who qualifies as a COIDA employer.
Many property company owners believe they don’t have “real” employees — they use managing agents, contractors, and service providers to maintain and manage their portfolio. The assumption is that COIDA doesn’t apply to them because they don’t have a permanent workforce.
It does. If a property company has any employee — a caretaker, a part-time cleaner, a maintenance person — on payroll for more than a few hours a week, they are a COIDA employer and must register and file an ROE. The minimum annual assessment for commercial employers is R1,621 regardless of payroll size. Most property companies in the non-compliant cohort are not avoiding a large assessment — they are simply unaware that the obligation applies to them at all.
Manufacturing — 77.3% non-compliant
Manufacturing non-compliance is an administrative resource problem. Owner-run manufacturing SMEs — metal fabricators, food processors, furniture makers — are typically running lean with no dedicated compliance or finance function. The owner handles everything from purchasing to staff management. The ROE deadline in April competes directly with production pressures, supplier payments, and customer delivery schedules.
Manufacturing also has a tariff complexity problem. COIDA industry classification is not straightforward for manufacturers — the correct class depends on the specific type of manufacturing activity, and the wrong classification means the wrong tariff rate. An employer who is uncertain whether they are Class C (which includes certain manufacturers) or another class may defer the ROE rather than file incorrectly and face a recalculation.
Healthcare — 76.2% non-compliant
Healthcare is the counterintuitive finding that should concern every medical practice owner most.
Healthcare workers face among the highest occupational injury risks of any sector: needlestick injuries, patient handling injuries, infectious disease exposure, chemical exposure, and ergonomic injuries from sustained clinical work. These are exactly the scenarios COIDA was designed to cover. Yet 76.2% of healthcare employers have an expired LOGS — meaning three in four healthcare workers are currently uninsured against the occupational injuries they are most likely to sustain.
The structural explanation: healthcare practice owners are clinically trained, not administratively trained. The practice manager handles most compliance, but COIDA falls between the SARS-facing accountant (who manages the financial compliance) and the HR-facing practice manager (who manages employment conditions). Neither party explicitly owns the ROE deadline. It is not on either person’s calendar. It lapses annually because nobody has accountability for it.
Financial Holdings — 74.1% non-compliant
This is the finding that should provoke the most uncomfortable self-reflection in any financial services boardroom.
Financial Holdings companies — investment holding entities, asset managers, financial advisers, and related businesses — manage money professionally. They have finance teams. They have compliance officers. They file detailed reports with the Financial Sector Conduct Authority. They manage other people’s money.
And three in four of them have an expired COIDA Letter of Good Standing.
The structural explanation is an ownership gap. COIDA is perceived as a labour compliance obligation rather than a financial one. The CFO does not own it — it is not a financial reporting requirement. The HR manager does not own it — it sits outside the UIF and employment conditions framework they manage day to day. Nobody has been explicitly assigned the ROE deadline, so nobody files it.
The irony is that the financial cost of non-compliance for a financial holdings company — potential personal director liability for a workplace injury, plus the 10% late penalty on the assessment fee, plus the cost of reinstating a lapsed LOGS — is precisely the kind of liability these companies are normally meticulous about quantifying and avoiding.
Retail and Trading — 72.6% non-compliant
Retail sits almost exactly at the national average. The absolute numbers are the real story here: 12,252 companies with expired LOGS out of 16,885 analysed. Retail is the largest sector in the dataset by volume, which means it carries the largest absolute concentration of non-compliant employers.
Retail non-compliance is diffuse rather than structurally concentrated. Small retailers typically have part-time and casual staff with high turnover, no dedicated HR function, and competing administrative priorities. The ROE calculation requires accurate payroll records for the prior year — for a retailer with variable headcount and split payroll periods, this requires consolidated records that are often not maintained consistently.
Security — 70.8% non-compliant
Security sits below the national average. The structural reason is identical to construction: tender requirements and client contract compliance checks enforce COIDA compliance commercially.
A security company that arrives to bid on a contract without a valid LOGS does not get the contract. The commercial consequence of non-compliance — lost revenue, lost contracts — is immediate and tangible. Security companies learn this lesson early and calendar the ROE deadline accordingly.
Construction — 70.4% non-compliant
Construction’s below-average performance is the clearest illustration of the enforcement paradox.
Tender requirements at government and corporate sites require proof of a valid Letter of Good Standing. Site-entry compliance checks mean a contractor arriving without a current LOGS cannot get on site. CIDB registration — required for government construction contracts — involves compliance verification. The financial consequence of non-compliance is felt immediately: you lose the contract before the work starts.
Contractors who lose contracts because of a lapsed LOGS file their ROE the next day. The enforcement pressure that tender requirements create is more effective than any regulatory awareness campaign.
COIDA tariff rates for construction reflect the sector’s genuine risk profile — construction carries higher rates than low-risk industries, which means the assessment fee is not trivial. The combination of non-trivial financial cost and immediate commercial consequence from non-compliance creates a population of construction employers who treat the ROE deadline seriously.
Cleaning — 69.3% non-compliant
Cleaning sits below average for the same structural reason as security. Cleaning companies working for corporate clients face compliance verification as part of supplier onboarding. The Cleaning Industry Bargaining Council enforces minimum wage compliance through inspections that often check COIDA status simultaneously. Commercial pressure enforces compliance where regulatory pressure alone would not.
Logistics — 68.3% non-compliant
Road freight operators face compliance requirements through the National Bargaining Council for the Road Freight Industry and through fleet operator licencing. The COIDA Letter of Good Standing is frequently required for fleet insurance and operator card renewals — creating the same commercial enforcement pressure as construction and security.
Services — 67.1% non-compliant
Services is a broad category that includes professional services firms — accountants, lawyers, consultants, HR practitioners. These businesses typically have better administrative infrastructure than manual labour sectors. The ROE is an annual task that sits on the accountant’s or administrator’s calendar.
The irony: the accountants who are most likely to be compliant themselves are the same people who frequently miss their clients’ COIDA obligations — because they do not own the COIDA deadline in the same way they own the SARS provisional tax calendar.
Automotive — 66.6% non-compliant
Franchise dealerships face compliance requirements from manufacturers as a condition of franchise agreements. Independent dealerships and repair shops are more variable. The relatively good performance in automotive reflects the franchise compliance pressure at the larger end of the sector.
Mining — 63.0% non-compliant
The DMRE (Department of Mineral Resources and Energy) builds compliance verification into operational licensing for mining operations. Shaft-entry compliance checks, annual licence renewals, and the constant risk of a Section 54 operational stoppage create an environment where HR and compliance teams treat the ROE window as a fixed annual event.
Rand Mutual Assurance, which administers COIDA for the mining sector separately from the Compensation Fund, provides a dedicated administration channel for mining employers. The sector’s compliance infrastructure is materially better than sectors left to navigate the Compensation Fund’s CompEasy system independently.
Engineering — 60.0% non-compliant (best performing)
Engineering is the most compliant sector in the dataset. The structural explanation is professional firm infrastructure.
Consulting engineers, structural engineers, and related professional firms typically have dedicated finance teams or accountants who treat regulatory deadlines as calendar events. ECSA (Engineering Council of South Africa) registration and professional indemnity insurance requirements create compliance verification touchpoints. The professional culture in engineering firms tends toward meticulous record-keeping.
The low claim rate in engineering — office-based professional work generates relatively few serious workplace injuries — also means the COIDA assessment fee is modest, which paradoxically increases the likelihood of filing it. The lower the financial burden, the lower the resistance to compliance.
The single insight across all 15 sectors
Compliance is not a function of awareness, ethics, or even capacity. It is a function of consequences.
Where non-compliance has an immediate, commercial, felt consequence — losing a tender, losing a client, failing a site inspection — employers comply. Where non-compliance is invisible until a labour inspector arrives or a workplace injury triggers a claim, employers don’t.
The implication for your business is direct. The ROE deadline will not remind you. The Compensation Fund will not chase you before your LOGS lapses. The penalty clock starts running automatically on 1 July — 10% added to your assessment the day the window closes, LOGS lapsed immediately. By the time you find out, you may already be personally liable for whatever happened between the expiry date and the day you discover it.
The 2026 ROE window closes 30 June 2026. That is five weeks from today.
Check your COIDA status before the window closes
Check your COIDA status now — free, 30 seconds — at clearcomply.co.za/check. If your Letter of Good Standing has lapsed, the fix guide inside ClearComply walks you through the ROE submission and payment process step by step.
ClearComply’s compliance calendar tracks your ROE deadline alongside CIPC, SARS, UIF, and POPIA obligations — automated reminders at 60, 30, 14, and 7 days before every deadline. From R49/month. The next ROE window opens April 2027. Set the reminder now and it will never catch you by surprise again.
For the underlying industry-by-industry data table behind every number in this analysis, see our companion piece, COIDA Compliance in South Africa 2026: Industry-by-Industry Analysis. For the COIDA employer onboarding fundamentals (registration, ROE, Letter of Good Standing), see our COIDA Compensation Fund guide. For the ROE deadline mechanics specifically, see the COIDA Return of Earnings guide. For the broader picture of what happens when SA businesses ignore compliance, see our non-compliance penalties guide.
Data: ClearComply’s analysis of employer compliance data across 188,920 South African businesses, April 2026. COIDA tariff and threshold data: Department of Employment and Labour gazette notices, 2025/2026 assessment year. Enforcement data: Department of Employment and Labour media statements, September 2024 and February 2026.