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HPCSA Rule 18 Explained: Employment Approval and Annual Reports for Psychology Professionals

HPCSA Rule 18 employment approval process for South African psychology professionals

HPCSA Rule 18 governs when a registered practitioner may accept employment from a person or entity that is not registered with the Health Professions Council of South Africa. In November 2025, the Council reinstated the requirement that these employers obtain approval before they employ a registered practitioner (Health Professions Council of South Africa, 2025a). Consequently, psychologists, registered counsellors and the practices that employ them now need to understand this process again. This guide explains what the rule requires, how employers apply through the OSVC portal, and how practitioners submit the annual report.

What HPCSA Rule 18 Requires in 2026

Rule 18 sits within the Ethical Rules of Conduct made under the Health Professions Act 56 of 1974. Specifically, it sets the conditions under which a registered practitioner may accept a professional appointment or employment from a non-registered person, such as a private company (Kirby et al., 2026). The rule has always mattered to private practice, but its requirements have shifted twice in recent years.

Between 17 November 2023 and 21 November 2025, non-registered entities could employ registered practitioners without HPCSA approval, provided a written contract served the interest of the public and the profession (Kirby et al., 2026). However, that window has now closed. On 21 November 2025, the Council published Board Notice 856 of 2025, which reintroduced the pre-approval requirement.

Under the amended rule, a practitioner may accept an appointment or employment only from an employer approved by the Council, and only under a written contract drawn up in the interest of the public and the profession (Kirby et al., 2026). Additionally, that contract must be available to the Council on request. As a result, employers who took on practitioners during the two-year interim period should consider whether they now need to apply.

Which employers are exempt

Not every employer must apply. In particular, the OSVC portal guidance lists three exempt categories (Health Professions Council of South Africa, 2025b):

  • The public service.
  • Training institutions such as universities, limited to the purposes of training and research.
  • NPOs and NGOs, subject to approval by the relevant professional board.

How Employers Submit an HPCSA Rule 18 Application

The employer, not the practitioner, submits the application to employ a registered practitioner. Moreover, the employer needs an existing profile on the HPCSA online services portal. A prospective employer without a profile should first contact the Council at professionalpractice@hpcsa.co.za to set one up (Health Professions Council of South Africa, 2025b).

Once logged in, the employer selects Application to Employ a Registered Practitioner and works through a short wizard. First, an introduction screen confirms the legal basis for the process. Next, the applicant verifies their personal and contact details and marks at least one primary address. Finally, the employer completes the application form and uploads supporting documents.

The information the form asks for

The employer application form asks for a written motivation across several areas. Therefore, it helps to prepare these responses before starting. The form covers the following (Health Professions Council of South Africa, 2025b):

  • The motive or goal of the proposed employment.
  • The specific group of patients to be served, such as non-profit or charitable populations.
  • The benefit of the employment to the practitioners.
  • How the contract protects the practitioner’s clinical independence.
  • The method of remuneration and how perverse incentives are avoided.
  • Clinical governance, management, and internal peer review arrangements.

After completing the form, the employer uploads the contract of employment and any additional documents, keeping each attachment under 5MB. On submission, the portal issues a service request reference number for all further correspondence with the Council.

Registering an Employed Practitioner After Approval

Approval is not the final step. Additionally, the employer must register the approved practitioner to link them to the entity, which is what later enables the annual report. From the portal home, the employer opens the Rule 18 service and selects Registering an Employee Rule 18.

The employer then searches for the practitioner using an identity number or registration number and selects the correct contact from the results. Subsequently, the employer confirms the registration details and category, uploads the contract of employment, and submits. As before, the portal returns a reference number to confirm receipt.

The HPCSA Rule 18 Annual Report Explained

The annual report is the practitioner’s responsibility, not the employer’s. The practitioner logs into their own profile, opens the Rule 18 service, and selects Annual Report Submission Rule 18. Notably, the report covers the 12-month cycle ending 31 March, and it may also be submitted at any time at the end of an employment contract (Health Professions Council of South Africa, 2025b).

After verifying their personal and contact details, the practitioner confirms the institution by selecting the relevant category and employer from a list. Next, they select their registration and category, then complete the employment details. These include the employer name, date and duration of employment, division or unit, and the supervisor or manager.

Finally, the practitioner provides feedback on three areas: clinical independence and autonomy, the method or type of remuneration, and decision-making protocols. After adding any further comments, the practitioner signs, records a place and date, and submits. Once again, the portal issues a reference number to confirm the submission.

What This Means for Psychology Practices

For most psychology employers, the practical message is straightforward. Specifically, private practices, group practices and companies that employ psychologists or registered counsellors should confirm whether they hold current Rule 18 approval. Practices that took on practitioners during the interim period may now need to apply (Kirby et al., 2026).

Importantly, the amended rule does not state that it applies retrospectively, and the Council has not yet issued guidance for practitioners and entities affected by the change (Kirby et al., 2026). Therefore, the cautious approach is to maintain a written contract that clearly serves the interest of the public and the profession, and to apply for approval where it is required. NPOs and NGOs should remember that their exemption still depends on approval by the relevant professional board.

When you are unsure how the rule applies to your situation, verify the current requirements directly with the Health Professions Council of South Africa.

Whether you are applying for Rule 18 approval or filing your annual report, keeping your CPD current is one less compliance task to manage. Explore our HPCSA-accredited CPD courses to stay compliant across the counselling, clinical, industrial, psychometry and registered counsellor categories.

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