VOASA wishes to update members on the implementation of the amended direct marketing regulations under the Consumer Protection Act, with reference to the National Consumer Commission’s Opt-Out Registry.

The amended Regulations introduced a new compliance framework for direct marketers, including the requirement for direct marketers to register with the NCC and to cleanse their direct marketing databases against the national Opt-Out Registry.  The NCC previously communicated that the period from 1 July to 30 September 2026 would serve as a transitional implementation period, with full compliance anticipated from 1 October 2026.

As at today (29 September 2026), however, the Opt-Out Registry has not formally been launched for general use by consumers and direct marketers, and we have not identified any formal NCC notice confirming that the registration and database cleansing functionality is operational.  Importantly, no formal notice postponing the implementation of the amended Regulations or extending the previously communicated 1 October 2026 compliance date has been issued.

The practical position is therefore that the amended regulatory requirements remain applicable, while certain obligations,  most notably the requirement to cleanse marketing databases against the NCC Opt-Out Registry cannot practically be implemented until the Registry and the necessary access mechanisms are made available by the NCC.

VOASA has accordingly written to the NCC seeking formal clarification on the implementation position and will advise accordingly.

Members should continue with their compliance preparations and should not treat the apparent delay in the operational launch of the Registry as a suspension or postponement of the Regulations.

Members are reminded that the CPA Opt-Out Registry and POPIA operate alongside one another. The fact that a consumer is not listed on the NCC Opt-Out Registry will not, by itself, necessarily provide a lawful basis for electronic direct marketing under POPIA.

VOASA is actively engaging with the NCC to obtain definitive guidance on the outstanding implementation issues. We will circulate the NCC’s response, together with any further practical guidance for members, as soon as formal clarification is received.

Until then, members should continue preparing on the basis that the amended direct marketing requirements are in force and that the necessary NCC registration and cleansing processes will need to be implemented as soon as the relevant functionality becomes available.