Regulatory Compliance
Data Protection Act No. 3 of 2021
Personal data protection and privacy regulations (Regulated by: Data Protection Commission)
Key Requirements
| Requirement | Status | Control | Evidence | Actions |
|---|---|---|---|---|
| Data Subject Consent Management | Compliant | Consent Management System | 3 documents | |
| Data Breach Notification (72 hours) | Partial | Incident Response Plan | 2 documents | |
| Data Protection Impact Assessment | Non-Compliant | Not Mapped | None | |
| Data Subject Rights Management | Compliant | Rights Management Portal | 5 documents | |
| Cross-Border Data Transfer Controls | Partial | Transfer Agreements | 1 document |
Bank of Zambia (BOZ) Regulations
Financial sector regulations and prudential requirements
Key Requirements
| Requirement | Status | Control | Evidence | Actions |
|---|---|---|---|---|
| Capital Adequacy Requirements | Compliant | Capital Management Framework | 4 documents | |
| Liquidity Risk Management | Compliant | Liquidity Management System | 6 documents | |
| AML/CFT Compliance | Compliant | AML Monitoring System | 8 documents | |
| Regulatory Reporting | Partial | Reporting Framework | 3 documents |
National Pension Scheme Act
Pension scheme administration and compliance requirements
Key Requirements
| Requirement | Status | Control | Evidence | Actions |
|---|---|---|---|---|
| Member Registration Process | Compliant | Registration Management System | 7 documents | |
| Contribution Collection & Recording | Compliant | Contribution Management System | 10 documents | |
| Benefits Administration | Compliant | Benefits Processing System | 12 documents | |
| Investment Management Guidelines | Compliant | Investment Policy Framework | 8 documents | |
| Actuarial Valuation Requirements | Partial | Actuarial Framework | 4 documents |
Employment Act of Zambia
Labor law compliance and employee rights protection
Key Requirements
| Requirement | Status | Control | Evidence | Actions |
|---|---|---|---|---|
| Employment Contracts | Compliant | HR Management System | 5 documents | |
| Working Hours & Overtime | Compliant | Time & Attendance System | 3 documents | |
| Leave Entitlements | Partial | Leave Management System | 2 documents | |
| Termination Procedures | Compliant | HR Policies & Procedures | 4 documents |
Competition and Consumer Protection Commission (CCPC)
Competition law and consumer protection compliance
Key Requirements
| Requirement | Status | Control | Evidence | Actions |
|---|---|---|---|---|
| Fair Competition Practices | Compliant | Competition Compliance Policy | 3 documents | |
| Consumer Rights Protection | Compliant | Customer Service Framework | 5 documents | |
| Merger & Acquisition Compliance | Partial | M&A Guidelines | 2 documents |
Anti-Corruption Commission Act
Anti-corruption and integrity compliance requirements
Key Requirements
| Requirement | Status | Control | Evidence | Actions |
|---|---|---|---|---|
| Anti-Corruption Policy | Compliant | Ethics & Integrity Framework | 6 documents | |
| Whistleblower Protection | Compliant | Whistleblower System | 4 documents | |
| Conflict of Interest Management | Compliant | COI Declaration System | 5 documents | |
| Gift & Entertainment Policy | Partial | Gift Register | 2 documents |
Regulatory Compliance Overview
Compliance Status by Framework
Upcoming Deadlines
Data Protection Act Annual Report
Due: Aug 31, 2025BOZ Quarterly Filing
Due: Sep 15, 2025NAPSA Benefits Audit
Due: Sep 30, 2025Recent Regulatory Updates
Data Protection Act Amendment - Data Localization
New requirements for personal data storage within Zambian borders. Effective date: January 1, 2026.
BOZ Circular - Enhanced KYC Requirements
Updated customer due diligence requirements for pension schemes. Implementation deadline: October 31, 2025.
Regulatory Compliance Guide
Comprehensive guide to managing regulatory compliance across multiple Zambian regulatory frameworks applicable to NAPSA operations.
1 Quick Start Guide
Review Frameworks
Navigate: Regulatory Frameworks tab
Review the 6 regulatory frameworks applicable to NAPSA: Data Protection, BoZ, NAPSA Act, Employment Act, CCPC, ACC Act.
Monitor Compliance
Check: Dashboard statistics
Monitor overall compliance percentage, active regulations count, compliance gaps, and upcoming deadlines.
Address Gaps
Action: Review compliance gaps
Identify non-compliant and partially compliant requirements, create action plans, and track remediation progress.
Track Deadlines
Monitor: Upcoming regulatory deadlines
Track submission deadlines for regulatory reports, filings, and assessments across all frameworks.
Run Assessments
Assess: Framework compliance status
Conduct compliance assessments (quick, detailed, gap analysis) for individual frameworks or all frameworks.
Generate Reports
Export: Compliance reports for regulators
Generate PDF reports for submission to regulators, Board, and management stakeholders.
2 Understanding Regulatory Frameworks
What are Regulatory Frameworks?
Regulatory frameworks are sets of laws, regulations, guidelines, and standards issued by government authorities that NAPSA must comply with. These frameworks govern various aspects of NAPSA's operations including data protection, financial management, pension administration, employment practices, competition, and anti-corruption measures.
NAPSA's Six Core Regulatory Frameworks
Data Protection Act No. 3 of 2021
Regulator: Data Protection Commission
Scope: Personal data protection and privacy regulations
Key Requirements: Consent management, breach notification (72 hours), data subject rights, cross-border transfers, Data Protection Impact Assessments (DPIA)
Bank of Zambia (BoZ) Regulations
Regulator: Bank of Zambia
Scope: Financial sector regulations and prudential requirements
Key Requirements: Capital adequacy, liquidity risk management, AML/CFT compliance, regulatory reporting, risk management frameworks
National Pension Scheme Act
Regulator: Pensions and Insurance Authority (PIA)
Scope: Pension scheme administration and compliance
Key Requirements: Member registration, contribution collection, benefits administration, investment management, actuarial valuations
Employment Act of Zambia
Regulator: Ministry of Labour and Social Security
Scope: Labor law compliance and employee rights protection
Key Requirements: Employment contracts, working hours & overtime, leave entitlements, termination procedures, workplace safety
CCPC Act
Regulator: Competition and Consumer Protection Commission
Scope: Competition law and consumer protection compliance
Key Requirements: Fair competition practices, consumer rights protection, merger & acquisition compliance, anti-competitive conduct prevention
Anti-Corruption Commission Act
Regulator: Anti-Corruption Commission (ACC)
Scope: Anti-corruption and integrity compliance
Key Requirements: Anti-corruption policy, whistleblower protection, conflict of interest management, gift & entertainment policy
3 Framework-Specific Compliance Requirements
Critical Requirements:
- Data Subject Consent Management - Obtain, document, and manage consent for personal data processing
- Data Breach Notification - Report data breaches to Data Protection Commission within 72 hours
- Data Protection Impact Assessment (DPIA) - Conduct DPIA for high-risk processing activities
- Data Subject Rights Management - Enable right to access, rectification, erasure, portability
- Cross-Border Data Transfer Controls - Ensure adequate safeguards for data transfers outside Zambia
- Data Protection Officer (DPO) - Appoint DPO and maintain independence
- Data Localization - Store personal data within Zambian borders (effective Jan 1, 2026)
Critical Requirements:
- Capital Adequacy Requirements - Maintain minimum capital ratios as prescribed by BoZ
- Liquidity Risk Management - Implement liquidity management framework and reporting
- AML/CFT Compliance - Know Your Customer (KYC), transaction monitoring, suspicious transaction reporting
- Regulatory Reporting - Submit quarterly and annual returns to BoZ (timely and accurate)
- Risk Management Framework - Establish comprehensive ERM framework (credit, market, operational, liquidity risks)
- Internal Audit Function - Maintain independent internal audit reporting to Board
- Board Governance - Board composition, independence, risk committee, audit committee
Critical Requirements:
- Member Registration Process - Timely registration of all eligible members
- Contribution Collection & Recording - Accurate recording of employer and employee contributions
- Benefits Administration - Timely processing of retirement, invalidity, and survivor benefits
- Investment Management Guidelines - Comply with investment limits and prudent person rule
- Actuarial Valuation Requirements - Conduct actuarial valuations at prescribed intervals
- Record Keeping - Maintain accurate member records for 75 years
- Financial Reporting - Annual audited financial statements submitted to PIA
Critical Requirements:
- Employment Contracts - Written contracts for all employees within 30 days of hire
- Working Hours & Overtime - Maximum 48 hours/week, overtime compensation at 1.5x
- Leave Entitlements - Annual leave (24 days), sick leave, maternity leave (90 days)
- Termination Procedures - Notice periods, severance pay, procedural fairness
- Workplace Safety - Occupational health and safety standards
- Equal Opportunity - Non-discrimination in employment
- Minimum Wage Compliance - Comply with national minimum wage requirements
Critical Requirements:
- Fair Competition Practices - Avoid anti-competitive agreements and abuse of dominance
- Consumer Rights Protection - Transparent service delivery, complaint handling
- Merger & Acquisition Compliance - Notify CCPC of mergers exceeding threshold (ZMW 20 million)
- Price Transparency - Clear disclosure of fees and charges
- Customer Service Standards - Maintain service level agreements
Critical Requirements:
- Anti-Corruption Policy - Board-approved ethics and integrity framework
- Whistleblower Protection - Anonymous reporting channel with protection against retaliation
- Conflict of Interest Management - Annual COI declarations by all staff
- Gift & Entertainment Policy - Gift register, approval thresholds, disclosure requirements
- Due Diligence on Third Parties - Vendor screening and ongoing monitoring
- Training & Awareness - Annual anti-corruption training for all employees
4 Compliance Monitoring & Reporting
Monitoring Process
-
Daily Dashboard ReviewCheck overall compliance percentage and critical gaps requiring immediate attention.
-
Weekly Framework ReviewReview each framework's compliance score, identify trending issues, and track remediation progress.
-
Monthly Compliance AssessmentConduct formal assessments for at least one framework per month (rotate across all 6 frameworks).
-
Quarterly Regulatory ReportingSubmit required reports to BoZ, PIA, and other regulators by statutory deadlines.
-
Annual Compliance ReviewComprehensive review of all frameworks, update compliance documentation, and present to Board.
Reporting Requirements
| Framework | Report Type | Frequency | Deadline | Recipient |
|---|---|---|---|---|
| Data Protection Act | Annual Compliance Report | Annual | August 31 | Data Protection Commission |
| BoZ Regulations | Quarterly Returns | Quarterly | 30 days after quarter end | Bank of Zambia |
| BoZ Regulations | Annual Financial Statements | Annual | March 31 | Bank of Zambia |
| NAPSA Act | Annual Financial Report | Annual | June 30 | Pensions and Insurance Authority |
| NAPSA Act | Actuarial Valuation | Triennial | December 31 | Pensions and Insurance Authority |
| Employment Act | NAPSA Contributions Return | Monthly | 10th of following month | NAPSA (for own employees) |
| All Frameworks | Board Compliance Report | Quarterly | Board meeting schedule | NAPSA Board of Directors |
5 Best Practices
DO's
- ✅ Review regulatory dashboard daily for compliance status
- ✅ Track upcoming deadlines at least 30 days in advance
- ✅ Maintain a compliance calendar with all regulatory submission dates
- ✅ Document all compliance activities and evidence
- ✅ Conduct internal audits before regulator examinations
- ✅ Assign dedicated compliance officers for each framework
- ✅ Subscribe to regulatory updates and circulars
- ✅ Maintain open communication with regulators
- ✅ Train staff on applicable regulatory requirements
- ✅ Archive compliance documentation for statutory periods
- ✅ Escalate compliance gaps to executive management immediately
- ✅ Integrate regulatory compliance with ERM framework
DON'Ts
- ❌ Don't wait for regulator queries to address compliance gaps
- ❌ Don't miss regulatory submission deadlines (penalties apply)
- ❌ Don't submit incomplete or inaccurate reports to regulators
- ❌ Don't ignore regulatory circulars and updates
- ❌ Don't assume partial compliance is acceptable
- ❌ Don't work in silos - compliance requires cross-functional collaboration
- ❌ Don't delay implementation of new regulatory requirements
- ❌ Don't treat compliance as a one-time activity (it's ongoing)
- ❌ Don't rely solely on external consultants (build internal capability)
- ❌ Don't forget to update policies when regulations change
- ❌ Don't ignore low-priority frameworks (all require attention)
- ❌ Don't fail to report breaches within statutory timeframes
6 Frequently Asked Questions
Answer: Each department has specific regulatory obligations:
- IT Department: Data Protection Act, BoZ (cybersecurity), NAPSA Act (systems availability)
- Finance: BoZ Regulations, NAPSA Act (financial reporting, investment management)
- HR: Employment Act, NAPSA Act (member contributions)
- Compliance: All frameworks (oversight responsibility)
- Customer Service: CCPC Act, Data Protection Act, NAPSA Act
- All Departments: ACC Act (anti-corruption applies to everyone)
Recommendation: Consult with the Compliance Department to identify your department's specific obligations.
Answer: Missing regulatory deadlines can result in serious consequences:
| Regulator | Late Submission Penalty | Additional Consequences |
|---|---|---|
| Data Protection Commission | ZMW 50,000 per day (up to 30 days) | License suspension after 30 days |
| Bank of Zambia | ZMW 10,000/day for first 7 days, ZMW 20,000/day thereafter | Regulatory restrictions, increased supervision |
| PIA | ZMW 25,000 per month | Mandatory compliance audit |
Answer: Use the Regulations module's built-in tracking:
- Identify Gaps: Click on any framework tab to see requirements with "Non-Compliant" or "Partial" status
- View Gap Details: Click "Action Required" or "Review" button to see specific deficiencies
- Create Remediation: Navigate to Compliance → Remediations and create action plan
- Assign Owner: Assign to responsible department head with specific due date
- Track Progress: Monitor remediation status (Open → In Progress → Completed)
- Re-Assess: Once remediation is complete, conduct follow-up assessment to update compliance status
Tip: The dashboard shows total compliance gaps - use this as your daily KPI to drive down to zero.
Answer: Assessment frequency depends on framework risk and regulatory requirements:
| Framework | Recommended Frequency | Rationale |
|---|---|---|
| Data Protection Act | Quarterly | High penalties, new regulations |
| BoZ Regulations | Quarterly | Aligns with quarterly reporting |
| NAPSA Act | Semi-Annual | Core operations, high compliance rate |
| Employment Act | Semi-Annual | Stable requirements, mature processes |
| CCPC Act | Annual | Lower risk, limited changes |
| ACC Act | Annual | High compliance rate, stable framework |
Answer: Regulators typically request the following types of evidence:
Documentation Evidence:
- Policies and procedures (approved by Board)
- Process flowcharts and workflow diagrams
- Training materials and attendance records
- Board and committee minutes
- Internal audit reports
Operational Evidence:
- System screenshots showing controls in action
- Sample transactions with approval trails
- Exception reports and management actions
- Incident reports and breach notifications
- Monitoring reports and dashboards
Testing Evidence:
- Control testing results
- Penetration test reports (for IT controls)
- User access reviews
- Reconciliation reports
- Compliance assessment reports
Answer: Stay informed through multiple channels:
- Official Regulator Websites:
- Data Protection Commission: www.dpc.gov.zm
- Bank of Zambia: www.boz.zm
- Pensions and Insurance Authority: www.pia.org.zm
- Competition and Consumer Protection Commission: www.ccpc.org.zm
- Anti-Corruption Commission: www.acc.org.zm
- Email Subscriptions: Subscribe to regulator newsletters and circulars
- NAPSA Compliance Department: Receives and disseminates all regulatory updates
- Industry Associations: Join pension fund industry associations for peer updates
- Legal Counsel: Engage external legal counsel for complex regulatory changes
- ERM System Alerts: System displays regulatory updates on Overview tab
7 Support & Resources
Compliance Department
Email: compliance@napsa.co.zm
Phone: +260 211 123 456 (Ext. 5200)
Hours: Monday-Friday 08:00-17:00
For regulatory interpretation, assessment guidance, compliance strategy, and coordination with regulators.
Legal Department
Email: legal@napsa.co.zm
Phone: +260 211 123 456 (Ext. 5300)
Hours: Monday-Friday 08:00-17:00
For legal interpretation of regulations, contract reviews, and liaison with external legal counsel.
IT Support Helpdesk
Email: itsupport@napsa.co.zm
Phone: +260 211 123 456 (Ext. 7000)
Hours: 24/7 Support
For technical issues with the ERM system, report generation, and dashboard access.
REGULATORY EMERGENCY HOTLINE
Phone: +260 977 123 456 (24/7)
For: Urgent regulator inquiries, data breaches requiring notification, critical non-compliance issues, regulator audit support