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Deadline looms for new compliance obligation for Section 18A-approved non-profits

Cape Town, 27 May 2025 – South African Public Benefit Organisations (PBOs) approved under Section 18A of the Income Tax Act have to comply with IT3(d) reporting, which impacts how tax-deductible donations are monitored and reported to the South African Revenue Service (SARS), by 31 May 2025.

This change is applicable to the 2024/2025 tax year (1 March 2024 – 28 February 2025), and non-profit managers must act now to ensure they remain compliant. Any receipt issued under Section 18A during the 2024/25 tax year must be captured and information submitted to SARS before the deadline.

“As the South African Institute for Advancement, Inyathelo is focused on strengthening the NPO sector and building awareness around compliance issues,” said Soraya Joonas, Finance Director at Inyathelo.

What is IT3(d) reporting?

IT3(d) is a third-party data submission process implemented by SARS to improve transparency and oversight of charitable tax deductions. It specifically applies to donations for which Section 18A receipts were issued. Similar to employer IRP5 submissions, IT3(d) submissions allow SARS to match taxpayer claims against receipts issued by PBOs.

Who must submit IT3(d)?

Only non-profits that are Section18A approved are currently required to submit IT3(d) returns. If the organisation is a registered PBO but does not have 18A approval, it is not yet obligated to comply with this reporting requirement.

What must be reported?

For each Section 18A receipt issued between 1 March 2024 and 28 February 2025, entities must submit the following:

  • Donor’s name, tax ID(optional) /ID or registration number(mandatory), and contact details
  • Donation amount and date
  • Receipt number
  • Type of donation (cash, in-kind, etc.)
  • Null submissions are still required if no receipts were issued.

When must IT3(d) be submitted?

Essentially, any receipt issued under Section 18A during the financial period from 1 March 2024 to 28 February 2025 must be captured and submitted.

SARS has introduced a biannual submission cycle for IT3(d), mirroring other third-party reporting:

  • Interim Submission: For the 6 months ending 31 August (due in October)
  • Annual Submission: Covering the full tax year (due in May of the following year)

For the 2024/2025 period, the first interim submission was due in October 2024, and the full year submission is due by 31 May 2025. 

Why does this matter?

This reporting is more than just red tape and serves to:

  • Validate Tax Deductions: Confirms the legitimacy of donor tax claims 
  • Promote Transparency: A step toward rebuilding financial credibility post–greylisting of the Financial Action Task Force (FATF) 
  • Modernise Compliance: Part of SARS’ digital tax ecosystem. 
  • Prevent Abuse: Minimises fraud and misuse of Section 18A receipts 

Joonas warned that failure to comply could jeopardise an entity’s PBO status or 18A approval.

 

How to prepare for this process

Nonprofit leaders should:

  • Verify their 18A approval with SARS.
  • Set up systems to track receipt data from the point of issue.
  • Coordinate with their software provider or IT team for compatible file formats if they issue more than 50 S18A receipts.
  • Train staff on required donor data fields.
  • Engage their accountant or tax advisor early to validate readiness.
  • Use the SARS Submission Channels: Use SARS e-Filing for manual report entries of less than 50 donation certificates or HTTPS for bulk uploads.

“NPOs are encouraged to stay up to date on the SARS IT3(d) submission developments as published on the SARS website, IT3 Data Submission | South African Revenue Service. The IT3(d) requirement brings both responsibility and opportunity. While it increases compliance demands, it also encourages stronger donor data practices, boosts public trust, and aligns the non-profit with evolving regulatory expectations,” said Joonas.

For further guidance, PBOs should consult their tax advisor, visit the SARS Third Party Data Submission platform and follow the Inyathelo social media pages for our upcoming annual tax webinar on S18A and IT3(d) submissions.