True, there is no requirement, but if the entity is not required to submit audited AFS, they may choose to submit unaudited AFS instead of a Financial Accountability Statement (FAS).
Per the CIPC website: “It should be noted that only the audited financial statements must currently be filed with the CIPC. A company or close corporation, that is not required to file its audited financial statements, may still file such or its reviewed financial statements via email@example.com
Companies and close corporations that is neither required to file its audited financial statements, nor voluntarily filed its audited financial statements or reviewed financial statements, must file a financial accountability supplement (CoR30.2) with its annual returns.
Please note that the information provided does not constitute legal or professional advice, but rather the applicability of existing theory to a given practical situation. Due care is taken to ensure that the information is correct, but it remains subjective and an interpretation of application of information.