RE1 vs RE5: which exam do you need?

The short answer: your role decides your exam. If you give advice or provide intermediary services to clients, you're a representative and you write the RE5. If you manage and oversee the FSP itself, you're a Key Individual and you write the RE1. If you're a sole proprietor, you're both people at once, so you write both exams. Everything else in this article is the detail behind that answer.

The two roles, in plain English

The FAIS Act splits a financial services business into doers and overseers. A representative is the person in front of clients: advising them, selling to them, handling their policies and investments. A Key Individual is the person accountable for the business behind that: the licence, the compliance function, the record keeping, the appointment and supervision of reps, and stepping in (up to and including debarment) when a rep goes wrong.

Each role has a first-level regulatory exam matched to what it's accountable for. That's the entire logic of the split.

Side by side: the numbers

• RE5: 50 questions, 2 hours, pass mark 66% (33 of 50), eight tasks.
• RE1: 80 questions, 2 hours 30 minutes, pass mark 65% (52 of 80), sixteen tasks, morning sittings only.
• Fee: currently R1 300 (VAT inclusive) per attempt for either exam; check Moonstone for the latest.
• Booking: both through Moonstone's portal at faisexam.co.za, registration closing 11 working days before each sitting.
• Both: multiple choice, four options, no negative marking, closed book, on paper at supervised venues.

Same legislation, different altitude

Both exams draw on the same core law: the FAIS Act, the General Code of Conduct, FICA, and the fit-and-proper requirements in Board Notice 194 of 2017. The difference is the altitude of the questions. The RE5 asks what a representative must do: what to disclose, when advice is suitable, how to handle a client's information. The RE1 asks what the person running the FSP must make sure happens: maintaining the licence, overseeing compliance and audits, managing FICA obligations across the business, and appointing, supervising and if necessary debarring representatives.

The official preparation guide backs this up with numbers. The RE1's sixteen tasks are close to a superset of the RE5's eight (a KI has to understand the rep's world to oversee it), and its published question mix leans more heavily on application and analysis. Broader and deeper, by design.

The deadlines work completely differently

This is the difference that catches people. A representative may work under supervision and must pass the RE5 within two years of their date of first appointment (the DOFA rule, per FAIS Notice 86 of 2018). A Key Individual has no supervision route: under Board Notice 194 of 2017 the exam must be passed before approval. So a rep's clock starts ticking after appointment, while a prospective KI's exam blocks the appointment itself.

Practically: if you're a rep, your deadline is set and you plan backwards from it. If you're becoming a KI, every week without the RE1 is a week your approval, licence application or promotion waits.

Who needs both?

Sole proprietors, for a start. A one-person FSP is its own Key Individual and its own representative, so Moonstone's guidance is explicit: you write both the RE1 and the RE5.

Beyond that, plenty of people hold both roles: the owner-adviser who runs the practice and still sees clients, or the branch manager who advises and oversees. Whether a particular dual-role case requires both exams has edge cases, and secondary sources disagree on some of them, so don't rely on a blog (including this one) for your specific situation. Confirm with your compliance officer or Moonstone. The safe general rule: if you genuinely perform both functions, prepare to write both.

Note also that the FSCA's Regulatory Examinations FAQ lists compliance officers under the RE1, alongside FSPs and Key Individuals.

If you need both: which first?

There's no official rule on order, so it comes down to your deadlines. If you're already appointed as a rep, the DOFA clock makes the RE5 the statutory priority. If a KI approval is holding up your licence or appointment, the RE1 is the one blocking business. And if neither deadline dominates, there's a real efficiency argument for writing them close together: the legislation overlaps heavily, so the FAIS, Code of Conduct and FICA knowledge you build for one paper carries straight into the other while it's still fresh.

Whichever you write first, the full guides cover each paper in detail: the complete RE5 guide for representatives and the complete RE1 guide for Key Individuals.

Preparing for either (or both)

The method doesn't change between the papers, because both are task-based exams: measure your per-task starting point, rebuild the weak tasks from the source legislation, practice application questions daily, and prove readiness with full timed mocks against the real pass mark. PassPath runs that engine for both exams, starting with a free 16-question readiness check for whichever you face first. It samples every task on your exam and shows your gap in about 15 minutes. Check your readiness free and start from where you actually stand.