This publication provides general industry information and should be read in context. It does not constitute regulatory approval, legal advice or independent supplier verification.
Missing an annual information submission, losing proof of a licence-fee payment or failing to record a material business change can turn routine administration into a licence risk. The licence holder remains responsible for keeping its information accurate, submitting recurring information and responding appropriately when the business changes.
A disciplined licence-year process reduces last-minute searches, inconsistent records and avoidable delays when customers, banks, insurers, suppliers or the regulator ask for current evidence.
Why Ongoing Compliance Matters
The regulator relies on information supplied by the licence holder. When ownership, contact details, operations or annual information change, the official record may need to be updated or supported by a formal process.
Ongoing compliance also protects the business commercially. Customers, banks, insurers and suppliers may request current evidence, and discrepancies can delay onboarding or transactions.
Maintain a Licence Master File
Create one controlled file containing the core licence record and all later correspondence. It should include:
- the original application and supporting pack;
- proof of lodging and publication;
- queries and responses;
- approval and issuance correspondence;
- the issued licence certificate;
- annual submissions and payment evidence;
- change notifications and amendment applications;
- current company records; and
- a register of important dates and contacts.
Store the records securely and ensure that more than one responsible person knows how to access them.
Track Annual Information Submissions
The DMPR currently publishes DMPR-30 as the Wholesale Licence Annual Information Submission form. The licence holder should use the current form and confirm the applicable submission period, supporting documents, payment requirements and delivery method.
Information may include business, ownership, employment, training, product-volume and other regulatory data required under the current framework.
Do not wait until the final date to reconstruct the year. Collect the relevant data throughout the operating period and reconcile it against accounting and transaction records.
Manage Annual Fees Separately
An annual information submission and an annual licence fee may involve related but separate evidence. Maintain proof of payment, the reference used and the date submitted.
Before payment, confirm the current amount and banking instructions through an official source. Fraudulent payment instructions can circulate in many sectors, and government payments should not be made solely on the basis of an unverified email.
Report Changes to Contact Information
Changes to the registered address, business address, telephone numbers, email address or other licence-holder details may require written notification within a specified period.
Use a formal internal trigger: when company information changes, the person responsible for company administration must notify the licence-compliance owner immediately.
Keep the notification, delivery proof and any updated certificate or confirmation in the licence file.
Ownership and Control Changes Require Care
Ownership changes can have consequences beyond a simple amendment. The applicable process depends on the nature and extent of the change and the current rules.
Before implementing a sale of shares, change of control, restructuring or transfer of the business, obtain advice on whether notification, amendment or a new application is required. Do not assume that the licence can be transferred with the company or business assets.
Business Model and Operational Changes
A wholesaler’s operating model may change over time. New products, regions, depots, suppliers or customer types can affect the supporting records and risk profile.
Maintain a change register for:
- storage and depot arrangements;
- supplier and manufacturer relationships;
- transport and insurance;
- business premises;
- product categories;
- major customer segments;
- directors and authorised representatives; and
- banking and financial controls.
Not every operational change necessarily requires a licence amendment, but every material change should be assessed.
Display and Protect the Licence
The current wholesale guidance refers to displaying the licence or a certified copy at the place of business. The original certificate should be protected against loss, alteration and unauthorised use.
Control who may send copies externally. When a copy is shared, record the recipient and purpose where appropriate. Licence copies can be misused in fraudulent offers if they circulate without control.
Respond to Regulatory Queries Properly
If the DMPR requests information, create a formal response file. Record the date received, deadline, responsible person, documents supplied and proof of delivery.
Responses should be complete, truthful and consistent with previous submissions. Where the request is unclear or material, obtain specialist advice before responding.
Build a Compliance Calendar
A simple calendar should include:
- annual information preparation and submission;
- annual licence fee confirmation and payment;
- insurance renewals;
- storage and transport agreement reviews;
- company-record reviews;
- professional or supplier-verification refreshes;
- training and capability reviews; and
- scheduled internal compliance audits.
Set reminders well before each date and assign a named owner.
Conduct an Annual Internal Review
Before completing the annual submission, compare the current business with the information originally supplied and later updated. Confirm that the licence-holder name, ownership, contact details and operations are correctly recorded.
Review whether the business has remained a going concern and whether the transaction records support the volumes and information being reported.
What FWA Licensed Membership Includes
FWA Licensed Membership is built around the work that continues after a wholesale licence is issued. It gives licensed wholesalers a structured place to manage recurring licence-year tasks instead of relying on memory and scattered files.
- assistance preparing the annual information submission using the current form and the member’s own records;
- wholesale licence-fee compliance reminders and support organising payment evidence;
- member courses, regulatory resources and practical operating guidance;
- access to the FWA Member Portal for structured member resources; and
- a clearer route for raising licensing and compliance questions with FWA.
Member responsibility remains: FWA does not replace the DMPR, legal or tax advisers, and membership is not a guarantee that a licence holder is compliant. The member must provide accurate information, approve submissions, make payments and meet applicable deadlines.
Review the annual petroleum wholesale licence compliance support available through qualifying Licensed Membership, compare the FWA membership options, or use the South African Fuel Pricing Centre when reconciling the official monthly price cycle with internal records and communications.
When Specialist Support Is Appropriate
External assistance may be useful where the licence holder has experienced an ownership change, lost records, received a regulatory query, missed a submission or needs to reconstruct historical compliance.
Support should improve the accuracy and organisation of the response. It cannot replace information that the licence holder is legally required to provide.
Keep the Licence Year Under Control
Join FWA for annual information-submission assistance, wholesale licence-fee compliance support, member resources and a structured operational workspace.
Official Reference
DMPR Petroleum Licensing Resources and DMPR-30
Important: Dates, forms, fees and procedures may change. Confirm the current requirements directly from the DMPR or a suitably qualified adviser before acting.
Fuel Wholesalers Association · South Africa