“My manufacturing business has been growing steadily and I expect it will go above the R50 million turnover mark this financial year. That said, its not a given, and I’m hesitant to spend on BEE planning before I’m sure we will go over this mark. Will I be able to first wrap up the financial year and thereafter do the necessary BEE expenditure and verify the business using management accounts for the first quarter after the financial year-end?”

In August 2020, the South African National Accreditation System (SANAS) issued a communication to B-BBEE verification agencies that measured entities shall not be permitted to conduct a B-BBEE audit using management accounts outside of their financial period. SANAS also encourages the use of financial statements rather than management accounts. 

However, given that a company’s financial audit may only be completed some time after their financial year-end and there could be urgency in obtaining a BEE certificate, a company would be allowed to use management accounts for the same period as their financial year for purposes of undergoing a BEE verification. 

So, to answer your question. You will not be allowed to verify using management accounts that fall in the period after your financial year. If a verification agency does allow this, which would be highly unlikely, you run the risk that should SANAS pick up this non-compliance, your BEE certificate could be cancelled.

Our advice is to rather conduct proper BEE planning now, an exercise that should in any event be conducted well in advance of your financial year-end, and in that planning evaluate the various scenarios for if your turnover fails to exceed/does exceed the R50 million turnover mark. With some careful planning and with the help of your BEE consultant you should be able to prepare for both scenarios and not run the risk of a poor BEE certificate due to inadequate planning.