Days of cover, licences, gas: the controls that move the rating
A rated register tells the board what it is exposed to. This guide is about what to do: for each of the ten risks, the control that moves the rating, the gap most commonly observed in the industry, and the evidence a board should ask for. Then where to start, what the first ninety days look like, and the five questions that tell you whether the register is finished. Part three of three.
How should an oil and gas company in South Africa manage risk?
Registers in this sector are seldom short of mitigations. They list contracts in place, policies approved, procedures followed. Often the residual rating sits close to where the inherent one did, because none of those things changed the likelihood or the impact. This guide sets out what does.
The test
Ask of every mitigationWhich?Does it reduce likelihood, reduce impact, or neither?If the answer is neither, it is an activity. Keep doing it, but take it off the register.
The evidence
Ask of every controlShow meA date, a number, a document, a test result"In place" is a claim. The board should be able to see the evidence itself.
The owner
Ask of every lineOne nameAt executive level, with the authority to spendA risk owned by a committee or a function is owned by nobody. A pattern observed across the industry: the gaps sit between two owners.
What counts as a control
Risk management in this sector is short of controls that can be shown to move a rating. The test is simple, and many registers in the industry fail it: a control is something that, if it works, makes the event less likely or the loss smaller, and that can be evidenced. An activity is everything else: the policy, the committee, the awareness campaign, the contract that exists.
A state petroleum group's own published risk list names oil price volatility, cyber threats, climate events and underutilised assets among its principal risks,9 and the industry's energy association puts energy security, the grid, policy and affordability at the top of its own.21 Those are the right lists. The question a board should ask about any such list is whether anything on the facing page would change the number if it failed. Where residual ratings stay high beneath a full page of mitigations, that is commonly the reason.
Each of the ten below is set out the same way: the control that moves the rating, the shortfall commonly observed, and the evidence a board should ask to see. Where the control moves likelihood rather than impact, or the reverse, it is marked, because the two call for different money.
Oil and gas best practices: the control for each of the ten risks
Each control is tied to the risk it treats and the strategic objective that risk threatens, numbered and scored as in guide 2, so the register and the controls read as one document. A control that cannot be traced to an objective should not be funded.
Control for risk 1: Supply interruption at port
A minimum cover set per depot and product, with a trigger that starts a defined response, reviewed weekly at exco alongside the cargo schedule. Where a second import point or terminal is available, a standing arrangement for it, tested. After the March 2026 diesel disruptions, a pre-buying watch: unusual forecourt demand is itself an early warning.17 The number of days is the board's call today, but the draft Strategic Petroleum Stocks Policy proposes a mandatory 21-day buffer for licensed wholesalers and importers, so a control built now should be built to that standard.20
Cover is measured but no trigger is defined, so the first exco discussion happens when a depot is already short. The second-terminal arrangement, where one exists, is verbal.
Days of cover by depot and product, this week and the trigger, against the proposed 21-day standard.20 The last date a cargo missed its window and what happened. The contract with the alternative terminal.
Control for risk 2: FX, slate and working capital
A board-approved treasury policy that says what FX exposure on cargoes is acceptable and how it is covered, the slate position and facility headroom reported monthly, and a working-capital model that shows the cash effect of a late cargo before it happens. For diesel, a documented pricing basis, given the regulator has said the mechanism is under review.17
Hedging is ad hoc and known to treasury alone. The slate is a line in the management accounts nobody outside finance reads. Working capital problems surface at the bank before they surface in the model.
The hedging policy and the current position against its limits. Headroom against the next two cargoes. The slate balance trend over twelve months.
Control for risk 3: Gas feedstock decline
A costed scenario at 1.5× and 2× gas cost on the board agenda, a conversion decision date set in advance, alternative-fuel permits applied for before they are needed, and a seat in the industrial gas users' collective purchasing discussions.12
One line in the register, owned by procurement, rated medium, with "monitor supplier communications" as the treatment. The decision date is the day the supplier gives notice.
The scenario, the decision date and who signs it. The permit application reference. The supply agreement's force majeure and allocation clauses, read.
Control for risk 4: Licence non-compliance and stop orders
Every licence condition, renewal date and ownership condition in one obligations register with a named owner, attested quarterly by the owners and annually by the CEO. Transactions screened against licence conditions before signature.3,7,14
Licences in a filing cabinet or a shared drive. Conditions discovered at inspection or at the Competition Commission. Two people each believe the other owns the renewal.
The register, filtered to renewals in the next twelve months. The last quarter's attestation. The screening memo from the last transaction.
Control for risk 5: Pipeline theft and product loss
Loss ratio per depot tracked monthly against metering tolerance, every variance above threshold investigated and closed, pipeline receipts reconciled to deliveries, and internal audit testing the reconciliation itself.
Losses absorbed into cost of sales and not reconciled. The metering tolerance is known to the depot manager only. Internal audit reviews the procedure document.
Loss ratio by depot for twelve months against tolerance. Open variance investigations and their age. Internal audit's last test of the reconciliation.
Control for risk 6: Environmental, safety and insurability
Directors briefed annually on their personal duty under NEMA section 34, spill and major-incident drills run and recorded, insurer survey recommendations implemented and closed within the year, and renewal terms and exclusions presented to the board rather than filed.1
An incident response plan that was last tested at commissioning. Insurer recommendations open for years. Cover reduced at renewal without the board being told.
The date and record of the last drill. The insurer survey and the status of each recommendation. This year's renewal terms, exclusions and limits against the worst-case loss.
Control for risk 7: Carbon tax escalation
The tax modelled to 2030 at Phase 2 rates in the budget and in every capex hurdle rate, allowance utilisation tracked, and the number treated as a strategic cost in the board's asset-life decisions.5
A tax line, accrued by finance, with no link to investment decisions. The 31% increase in 2026 arrived as a surprise in the management accounts.
The 2030 model and its assumptions. The hurdle rate with and without carbon. Allowance utilisation for the last tax period.
Control for risk 8: Single-supplier dependency
Every single point of failure named on a map. For each, a documented alternative, which for the inland pipeline usually means road, with contracted call-off capacity and a tested activation. Supplier financial health reviewed with the same discipline as customer credit.
Dependency known; the alternative "would be arranged if needed". It has not been tested. Supplier financial distress is learned from the news.
The map. The contract and permit for each alternative. The last test date and result. The supplier review schedule.
Control for risk 9: Cyber and operational technology
Operational technology in the asset register and owned by a named executive, OT network segregated from corporate IT and the segregation tested, an incident exercised with the terminal operator, and control-system patch status reported alongside IT.
OT is engineering's, security is IT's, and neither owns the boundary. The last penetration test covered email. Control systems run software nobody is allowed to patch.
The OT asset list and its owner. The segregation test result. The incident exercise report. Patch status on control systems.
Control for risk 10: Long-term demand and policy shift
A signpost list reviewed annually by the board: the fuel price review, the SANPC Bill, new-energy vehicle share, the carbon trajectory. Asset lives and site investment tested against deregulation and EV scenarios before capital is committed.1,10,18
The strategy assumes today's price mechanism and demand indefinitely. The signposts are read in the press. Petrol-sized assets are approved on petrol-era volumes.
The signpost list and the date of its last review. The scenario test attached to the last site investment. Who owns the list.
Where to start: most movement for least money
Not all ten cost the same to treat. Four are mostly discipline and can be largely addressed inside a quarter with little capital. Three need a structural decision the board has to make. The rest sit in between. Start with the first group; it earns the credibility for the second.
The first ninety days
What a focused programme can realistically deliver from a standing start, with an executive sponsor and a risk function of one or two people. Three deliverables a month, each of them something the board can see.
- Obligations register: every licence, condition, authorisation and renewal date, with an owner
- Days-of-cover report by depot and product, with the trigger level agreed at exco
- Loss ratio by depot for the last twelve months against metering tolerance
- The ten risks rated inherent and residual with the executive owners in the room, each owner signing their line
- OT asset list and owner named; segregation test commissioned
- Gas scenario at 1.5× and 2× cost built, decision date proposed
- First board risk report: ten risks, heat map, evidence per control, actions with dates
- Hedging policy and working-capital model tabled for approval
- Section 34 briefing delivered; insurer recommendations status presented
At day ninety the board has a register it can defend to an auditor, a regulator or a lender. The structural decisions on gas, hedging and the second route are on the agenda with a date, which is the most a ninety-day programme can honestly promise.
Risk management in oil and gas: running the register
One register, not two. Four of the ten are compliance risks. The obligations register and the risk register are maintained as one, each risk pointing to the obligations that give rise to it, each obligation pointing to the risk it feeds. One owner per line.
A cadence the board can rely on. Monthly at exco: days of cover, slate, loss ratios, open actions. Quarterly at the audit committee: the ten with residual ratings and evidence. Annually at the board: the inherent view refreshed, the signpost list reviewed, the appetite statement reconfirmed.
Evidence held on the line. The register lives in a workspace where the control evidence is attached to the line: the test result, the attestation, the renewal certificate. A report generated from it is current by construction; a report assembled for the meeting is current for the meeting.
Appetite stated in numbers. Days of cover, open FX position, loss ratio tolerance, licence renewals outstanding. A statement the board can test each quarter.
Five questions for the board
If the executive team cannot answer these in a sentence each, the register needs work before the next audit committee.
How many days of diesel cover do we hold at each depot, and what happens on the day after?
A number and a trigger, by depot.
Which of our licence conditions has a renewal date in the next twelve months?
If the answer takes more than a day to produce, the obligations register does not exist in a usable form.
What does the business look like at twice today's gas cost, and on what date do we decide?
With a decision date for the alternative.
Who personally carries the NEMA duty of care, and when were they last briefed?
Section 34 liability is personal. Directors should know they hold it. The same question applies to this year's insurance exclusions.
Which single node, if it failed tomorrow, would stop us trading, and what is the tested alternative?
Documented, permitted, tested.
How mature is the function
Five levels. Across the industry most operators sit at two or three; audit committees that accept a risk report without rework are typically looking at a level-four function. Five is rare and is mostly a matter of the register being lived in rather than maintained.
Top risks agreed in 5 days
Giving an oil and gas operator a clear view of its top risks
- Manguzvane, Mnguni, Mofokeng and Nesengani, Running on empty? South Africa's refinery closures and their macroeconomic impact, South African Reserve Bank, Occasional Bulletin of Economic Notes OBEN 2601, March 2026. Import share, installed and operational capacity, closure dates, R76 billion avoidable import bill.
- Wits University / TIPS, A sharp fall in gas supplies in 2028 threatens SA's economy, July 2026. Decline timing, Sasol allocations, IGUA employment estimate, LNG terminal status.
- Cliffe Dekker Hofmeyr, The President signs the Upstream Petroleum Resources Development Act, 1 November 2024. Act 23 of 2024, assent 25 October 2024, 20% state carried interest, 10% minimum black participation, commencement by proclamation.
- Department of Mineral Resources and Energy fuel price structure, 2026, as reported by TopAuto. Component values for inland 95 petrol; shares calculated and rounded by KeyDimension.
- Anthesis, South African carbon tax update: 2026 Budget highlights. R308 per tonne from 1 January 2026, Phase 2 to 2030.
- Freight News, OR Tambo fuel drought due to KZN floods, 26 April 2022. Jet fuel stock at about three days of demand against a normal seven.
- Bizcommunity, UAE oil company agrees to R16bn deal to buy Shell's SA fuel stations, 7 July 2026. Buyer, deal value, 580 sites, closing expected 2027, 28% empowerment stake.
- Engineering News, New national petroleum company aims to boost energy, fuel supply security, 14 May 2025. SANPC formation from PetroSA, SFF and iGas under the CEF.
- Central Energy Fund SOC Ltd, CEF Group Integrated Annual Report 2024/25, approved 30 September 2025. Group structure, SANPC Refinery acquisition and feasibility study, Rompco ownership, Saldanha and Coega LNG and Komatipoort projects, draft strategic stocks policy, principal risks.
- Cliffe Dekker Hofmeyr, Key changes in the 2026 SANPC Bill, 17 June 2026, and African Energy Chamber, SANPC enters stabilisation phase, targets full operations by 2027, November 2025. Bill B2-2026 introduced 11 February 2026; mandate, asset transfer, staff numbers, operational timeline.
- Stakeholder map: the power-interest grid after Mendelow (1991); King V Report on Corporate Governance (stakeholder relationships); Public Finance Management Act 1 of 1999, section 54 (Treasury approval of significant transactions by public entities). Placement of bodies on the grid is KeyDimension's assessment.
- Engineering News, More intentional effort and coordination needed to avert gas crisis, 10 April 2026. Rompco customer base, 185 PJ demand, industrial gas prices, Richards Bay and Durban LNG status, IRP 2025 gas targets.
- Green Building Africa, TNPA and Ukwanda LNG sign R22 billion Port of Ngqura gas terminal agreement, 31 May 2026. Term, value, 3,000 MW allocation, 2035 target.
- Vivo Energy, Engen and Vivo Energy combination completed, 21 May 2024. Petronas 74% stake sold, Phembani 21% of the South African business.
- Reuters via TankTerminals, Trafigura among three bidders for minority stake in Natref, 6 May 2026. 36.36% stake, 108,500 b/d, bidders.
- Parliament of South Africa, Committee chairperson welcomes court judgement in favour of CEF and SFF, 20 November 2020. Reversal of the 2015 strategic crude sale.
- Engineering News, Diesel disruptions and early hikes point to possible gap in pricing framework, 25 March 2026. No physical shortage, contract pricing above reference, R9.81 under-recovery, diesel pricing review.
- Bizcommunity (Reuters), South Africa EV sales this year race past last year's total, 3 November 2026, citing naamsa. NEV sales and share.
- Africa International Advisors, Storage as security: rethinking South Africa's liquid fuels resilience, 30 March 2026, citing DMRE and NERSA 2025 data. Storage and days of cover by region and product.
- Daily Maverick, We do the maths on Mantashe's new plan to secure South Africa's fuel, 16 July 2026. Draft Strategic Petroleum Stocks Policy 2026: 21-day private obligation, 70/30 split, replenishment deadlines, SANPC role.
- South African National Energy Association, South African Energy Risk Report 2024-25 Summary. Industry risk list: energy security, grid, policy, affordability; gas window closing.
Risk ratings, "what good looks like" and the board questions are KeyDimension's own, based on industry observation. Figures are rounded and were current at the date of publication.
This guide is general commentary and not advice on any specific organisation. Controls described are typical and illustrative. Figures are rounded and sourced as noted.