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Practice 03 · EE, skills, POPIA and OHS

Contracts, policies, Employment Equity, skills, POPIA and OHS

The paperwork that decides most disputes, done properly and kept current.

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What does this practice cover?

LabourLink drafts contracts of employment and a 41-policy suite, prepares Employment Equity plans and EEA2 and EEA4 reports, handles skills development submissions, sets up POPIA and PAIA compliance and works out the health and safety appointments a workplace needs. A compliance audit is usually the first step.

The law it rests on

Official texts linked. Last reviewed 17 October 2026.

A hand holding a pen over a printed document under review
Photograph: Mikhail Nilov on Pexels.

What is included

  • A compliance audit in the first thirty days
  • Contracts of employment, codes of conduct and disciplinary codes
  • A suite of 41 policies and 31 agreements, kept current when the law moves
  • Designated employer checks, the s24 senior manager and consultative forums
  • Employment Equity plans and EEA2 and EEA4 reports
  • Skills development facilitators, training committees, WSP and ATR submissions
  • B-BBEE consulting for the skills and employment equity elements
  • POPIA and PAIA compliance, including consents and the PAIA manual
  • Health and safety appointments under OHSA ss16, 17 and 19

On the People Dashboard

Employment Equity, B-BBEE and Skills tabs; OHS appointments calculator; POPIA and PAIA pack; consents register.

How the People Dashboard works

How it runs

  1. Audit

    A structured review of contracts, policies, registers and returns.

  2. Report

    A ranked list of gaps, each tied to the section it breaches.

  3. Fix

    Documents drafted, signed electronically and filed on the dashboard.

  4. Maintain

    Reporting dates diarised and policies updated when the law changes.

Common questions

General information on South African labour law, not legal advice on your facts.

Other practices

Is my business a designated employer under the Employment Equity Act?

Since 1 January 2025 you are a designated employer if you employ 50 or more employees. The annual turnover thresholds no longer apply. Municipalities, organs of state and employers designated by collective agreement are also covered.

Legal basis
  • Employment Equity Act 55 of 1998, s1, as amended by Act 4 of 2022 IN FORCE
What to do
Designated employers must consult, analyse, prepare an EE plan, assign a senior manager and report each year. Under the 2025 Regulations, online reports may be submitted from 1 September to 15 January.
When to escalate
Sectoral numerical targets were published in April 2025. Check the targets for your sector before you set numbers.
Sources
  1. Employment Equity Act 55 of 1998 (gov.za), s1, definition of designated employer
  2. Employment Equity Amendment Act 4 of 2022, Government Gazette 48418 (gov.za), s1(a)
  3. Proclamation 231 of 2024: commencement of the Employment Equity Amendment Act on 1 January 2025, Government Gazette 51684 (gov.za), commencement 1 January 2025
  4. Employment Equity Regulations, 2025, GoN 6125, Government Gazette 52515 (gov.za), reporting periods
  5. Determination of Sectoral Numerical Targets, GoN 6124, Government Gazette 52514 (gov.za), sectoral targets

By the LabourLink editorial team. Last reviewed 17 October 2026. General information, not legal advice.

What is the section 24 senior manager?

A senior manager that every designated employer must assign, with the authority and means to monitor and implement the Employment Equity plan. The employer remains liable for compliance.

Legal basis
  • Employment Equity Act 55 of 1998, s24 IN FORCE
What to do
Appoint the manager in writing, give them a budget and record their reports to the board.
When to escalate
Assigning a manager does not relieve the employer of its own duties under the Act.
Sources
  1. Employment Equity Act 55 of 1998 (gov.za), s24

By the LabourLink editorial team. Last reviewed 17 October 2026. General information, not legal advice.

When must an employer appoint health and safety representatives?

An employer with more than 20 employees in a workplace must designate health and safety representatives: at least one for every 50 employees, or one for every 100 in shops and offices. Where there are two or more representatives, a health and safety committee is required.

Legal basis
  • Occupational Health and Safety Act 85 of 1993, ss17 and 19 IN FORCE
What to do
Record the designation, train the representatives and minute committee meetings at least every three months.
When to escalate
An inspector may direct an employer to designate more representatives, including at workplaces with 20 or fewer employees.
Sources
  1. Occupational Health and Safety Act 85 of 1993 (gov.za), ss17 and 19

By the LabourLink editorial team. Last reviewed 17 October 2026. General information, not legal advice.

What does POPIA require of employers handling employee information?

Employers must process personal information lawfully, for a defined purpose, with security safeguards, and tell employees what is collected and why. Health, union and biometric data are special personal information with stricter rules. The Information Officer must be registered with the Information Regulator.

Legal basis
  • Protection of Personal Information Act 4 of 2013 IN FORCE
  • Promotion of Access to Information Act 2 of 2000, s51 IN FORCE
What to do
Issue an employee privacy notice, keep a retention schedule and compile a PAIA manual where required.
When to escalate
Report security compromises to the Regulator and affected people as soon as reasonably possible.
Sources
  1. Protection of Personal Information Act 4 of 2013 (gov.za), ss11, 18, 19, 22, 26 and 55
  2. Promotion of Access to Information Act 2 of 2000 (gov.za), s51
  3. Information Regulator (South Africa), official website, registration and complaints

By the LabourLink editorial team. Last reviewed 17 October 2026. General information, not legal advice.

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