SARS Is Threatening to Withdraw PBO and Section 18A Status – What NPOs Must Do Now

Over the past few weeks, SARS has sent formal notices to Public Benefit Organisations (PBOs) across South Africa.

The message is clear: address your compliance gaps or lose your PBO approval and Section 18A status entirely.

These notices are not only going to organisations that did something deliberately wrong. Many of the affected NPOs simply missed a submission cycle, declared an incorrect figure, or let a record-keeping gap slip through. SARS is not distinguishing between intentional non-compliance and honest admin oversights.

If you have received a notice, you have 21 business days to respond. If you have not received one yet, this is still the time to act.

What SARS Is Targeting

Based on the notices we have seen, SARS is flagging four specific areas:

• IT3(d) submissions not filed for one or more reporting periods (February and August cycles)
• IT12EI income tax returns not submitted
• Section 18A receipt values incorrectly declared on the IT12EI annual return
• General non-compliance with Section 30(3) of the Income Tax Act

Important: SARS has made it clear that organisations must address every area of non-compliance, not just IT3(d). A partial response will not protect your PBO status.

What Is at Stake

If your PBO status is withdrawn, the impact is immediate and hits both your organisation and your donors.

• Your NPO becomes a fully taxable entity, including income tax on all donations received
• You can no longer issue valid Section 18A certificates, and donors cannot claim deductions, even for certificates already issued
• Donors may become liable for 20% Donations Tax on contributions to your organisation
• VAT concessions, Transfer Duty exemptions, and Capital Gains Tax relief all fall away
• Donor confidence drops and cash flow takes a significant hit

What to Do Right Now

Whether or not you have received a notice, run through these five checks today. The sooner you find a gap, the simpler the fix.

1. Verify your IT3(d) submissions on eFiling for every period, including both the February and August cycles.
2. Confirm your IT12EI return has been filed and that the Section 18A values declared are accurate.
3. Review your founding document and make sure it reflects your SARS-approved Public Benefit activities.
4. Prepare your financial statements and an objectives summary in case SARS requests them.
5. If you have received a notice, respond within the 21 business day deadline. Do not wait.

How ActiveDonor Helps You Stay Compliant

ActiveDonor was built specifically for Section 18A donation management and IT3(d) submissions.

Here is what we can do for you right now.

• One-click IT3(d) submissions.
  Submit directly to SARS from within the platform. No manual file prep, no eFiling back and forth.
• Fast-track onboarding for backlogs:
  Have outstanding submissions? Bring in your existing Section 18A receipts and donor records. We will help you prepare IT3(d) returns for prior periods so you can catch up quickly.
• Compliance built into every donation
  ActiveDonor generates SARS-compliant Section 18A certificates and gives you the reporting you need to accurately declare values on your IT12EI return, every time.

If you need to get compliant urgently, reach out and we will prioritise your onboarding: