Effective 1 September 2025, the National Credit Regulator has issued Circular 09 of 2025, introducing a major change in how Debt Counsellors update consumer records on the NCR Debt Help System.

Instead of waiting for NCR dhs updates team to process emails, debt counsellors are now re-empowered and accountable to directly capture routine DHS status codes. This change eliminates delays, strengthens accountability, and gives consumers faster, more transparent outcomes.

What Changed in Circular 09 of 2025

The Circular clarifies that Debt Counsellors must action DHS updates themselves for the following status codes:

• B, G, G1, I and J (see NCR DHS Status Descriptions and requirements to update each status here)
• F1 and F2 (is treated with the same documentation and accountability standards)

Key Takeaways:

• Registered Debt Counsellors are accountable for both updates and supporting documentation.
• Consumers will benefit from faster updates and no more post court order limbo.
• Attorneys must align by handing over proof and requiring DHS implementation.
• The NCR reiterate on maker checker audits and strict compliance controls which are non-negotiable.

Why this Matters for Consumers

Faster DHS Updates for Consumers

• Debt counsellors now update the NCR Debt Help System (DHS) directly using the court orders and documents they already hold. This removes unnecessary delays and gives consumers faster certainty that their status is correctly updated.

No More Post Court Order Delays

• Previously, many consumers were stuck waiting after obtaining court order declaring them no longer over indebted or the removal thereof because the NCR DHS was not updated promptly. With Circular 09 of 2025, debt counsellors must complete this step themselves, ending the administrative “limbo” and ensuring that the credit providers and credit bureau systems stay in sync.

Debt Counsellors Are Fully Accountable for DHS Updates

• Responsibility is no longer spread across the NCR DHS updates team, attorneys, and/or clerks. The debt counsellor on record is now the one responsible for updating DHS, keeping proof, and correcting errors. This gives consumers a single accountable party.

Improved Accuracy in the Debt Review Administration

• By allowing the debt counsellor who holds the original documents to perform the DHS update, the risk of mistakes caused by third-party relays or transcription errors is reduced. This results in more reliable records at credit bureaus and fewer disputes.

Transparent Costs in the Debt Counselling Process

• DHS updates have been part of a debt counsellor’s defined duties as per their registration conditions and the National Credit Act, and this new revised procedure should be not treated as an optional extra. Therefore, consumers should not face hidden admin charges or unnecessary delays. These updates are included in the service already provided under debt counselling.

Pro-Consumer tip: Always request proof of update or be copied on all communication.

DHS Status Codes in Scope

For ease of reference, you can consult the below table containing the NCR DHS descriptions together with the changes post and pre-revision.

STATUS CODE	DESCRIPTION	PRE-REVISION	POST-REVISION
A	Applied for debt counselling	DC activates	DC activates
B	Application rejected	NCR updates	DC updates
C	Declared over-indebted	DC updates	DC updates
D3	Debt restructuring started (court)	DC updates	DC updates
D4	Debt restructuring completed	DC updates	DC updates
F1	All debts settled except mortgage	DC updates	DC updates
F2	All debts settled	DC updates	DC updates
G	Court order: not over-indebted	NCR updates	DC updates
G1	Voluntary withdrawal / order rescinded	NCR updates	DC updates
I	Consumer deceased	NCR updates	DC updates
J	Consumer sequestrated	NCR updates	DC updates

Implementation & Compliance (Effective 1 September 2025)

1. From 1 Sept 2025, Debt Counsellors must perform DHS updates for codes B, G, G1, I and J.
2. Updates must be accompanied by uploading authentic supporting documents (e.g., court orders, paid-up letters, PDA schedules). – (see requirements to update each NCR status code and documents required here)
3. Debt Counsellors are warned against updating the NCR DHS without proper documents and failue to adhere to this will be treated as prohibited conduct and a breach of registration.

DHS Updating: Accuracy, Responsibility & Accountability

• Only registered NCR debt counsellors may access DHS.
• Continuous updates are a condition of registration.
• A Debt Counsellor may only update DHS for consumers listed under their profile.
• If DC Registration Lapses the Consumer must transfer to another active Debt Counsellor to continue updates.
• Debt Counsellors will remain personally liable for all updates and documents, even if someone else uploads them unlawfully. (It is therefore imperative that the debt counsellor does not share his or her access to his or her DHS login credentials or issue documents (incl. Form 19) with an unregistered debt counsellor and/or if they are not the DC of record or a third party)

Gold Standard SOP for Debt Counsellors

Pre-update checks

• Confirm basis for the code change.
• Assemble full evidence pack (As listed here).
• Select exact code and craft concise reason.

DHS capture

• Log into DHS → Change Consumer Status → Select Status.
• Enter reason, attach docs (where possible).
• Save proof.
• Notify consumer, Bureaus, PDA, CP’s, and/or attorneys.

Maker Checker controls

• The Debt Counsellor performs the DHS update and records the reason with supporting evidence.
• Should there be multiple DC’s, A senior staff member or peer must review the update within 24–48 hours to confirm the correct status code was used and the evidence supports the change.
• At least 10% of all DHS updates should be sampled monthly by management or compliance staff. Findings must be recorded, and any errors corrected with retraining where needed.

When not to update

• Disputed or unclear facts.
• Pending court judgment.
• Code uncertainty.
• DHS system limitation.

Guidance for Attorneys on DHS Updates

• Include undertakings in court orders which should explicitly require the debt counsellor of record to update DHS within a set timeframe.
• Deliver all supporting documents to the Debt Counsellor immediately after judgment.
• Request written proof of DHS, Bureaus and Credit Provider updates within 3–5 business days.
• If the original Debt Counsellor is unresponsive or deregistered, consumers may appoint a cooperating Debt Counsellor solely to implement DHS updates.

Responsibilities for PDAs and Credit Providers

• Ensure your internal records and systems match the relevant DHS update within 5–10 business days.
• Adjust the payment schedules to reflect the new status.
• Trigger credit bureau updates and reporting changes promptly where applicable.
• Provide written confirmation back to the debt counsellor, attorney, or consumer once aligned.

What Consumers Should Expect

1. Your debt counsellor is accountable and must complete the DHS update.
2. Updates should be made within a few days after the necessary documents are finalised or obtained.
3. Always ask your DC for the DHS, creditor and bureau update receipt or screenshot.
4. You must expect credit providers and relevant bureaus to reflect the new status shortly after or as per Circular 02 of 2022.
5. If delays occur, escalate in writing to your Debt Counsellor, and if needed, to the NCR. Learn How to Get Your Debt Counselling Complaints Resolved in 24 Hours

Evidence, Retention and Audit Requirements for Debt Counsellors

1. Keep full evidence packs – This will include all court documents, correspondence, paid up letters etc.
2. Save files under standardised names (e.g. 2025-09-01_DHS_Update_G1_ID90001*****180.pdf).
3. Fix any errors quickly, notify all affected parties, and retrain staff.
4. Debt counsellors remain personally responsible for the accuracy of updates, regardless of who uploaded them.

Why this is a Turning Point for Debt Counselling

NCR Circular 09 of 2025 is a game-changer for debt counselling in South Africa.

By shifting DHS updates directly to debt counsellors, the system becomes faster, more accurate, and more accountable. Consumers benefit from fewer delays and greater transparency, while attorneys, PDAs, bureaus and credit providers can operate with clearer responsibilities.

For debt counsellors, the Circular raises the bar, strict documentation, proper audit trails, and personal accountability are now non-negotiable.

How to Simplify Compliance with the My Debt Counselling System

Circular 09 demands precision, documentation, and speed. That’s exactly what My Debt Counselling Software for Debt Counsellor was built for.

1. CRM built for all of your debt counselling needs – manage clients, matters, and communications in one place.
2. Debt Review & Removal automation – generate all necessary removal and status-update documents instantly.
3. Client notifications – send compliant, branded updates to consumers, creditors, bureaus and PDAs automatically.
4. Integrated with a registered PDA
5. 100% compliant with the National Credit Act & NCR and designed for audit ready evidence retention and reporting.

With the My Debt Counselling System, debt counsellors can streamline everything Circular 09 requires: from DHS updates and evidence packs to consumer notifications and compliance logs.

My Debt Counselling is available to registered DCs through a secure platform. For access, request a demo or speak to our team. Approved users receive login credentials with two-factor authentication and NCR-compliant onboardings. Contact us on 0410125036 or send a WhatsApp to 0727703674

If you are a client and would like assistance, please book an appointment with us using the link below.

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