Must I file IT3(d) if no Section 18A receipts were issued?

Direct answer

Yes, if the entity has SARS approval to issue Section 18A receipts but issued no tax-deductible receipts for the reporting period, SARS requires an IT3(d) null declaration. An exempt institution that does not have Section 18A approval does not submit IT3(d) merely because it received donations.

The null declaration can be completed on eFiling after the IT3 tax type and IT3(d) product are activated. Use the reporting period and deadline shown in the current SARS notice and eFiling work page.

What this means in practice

Zero receipts is a reportable result, not a reason to ignore the submission. First confirm the exact approval held by the entity. PBO approval and Section 18A approval are related but not identical. The approval letter should show whether the entity may issue deductible receipts and for which activities.

Do not create R0 donor certificates to force a submission. The null declaration is the proper route when there are no receipts.

Step-by-step

1. Read the SARS approval letter and confirm Section 18A status.
2. Reconcile the donation ledger and receipt register for the reporting period.
3. Confirm that no Section 18A receipts were issued, including cancelled or corrected sequences.
4. Ensure the registered representative is current and activate IT3 on eFiling.
5. Open the IT3(d) product for the applicable period and select the null-declaration option.
6. Review the declaration, submit it and save the SARS confirmation.
7. Reconcile the annual financial statements, IT12EI and future IT3(d) data to the same underlying records.

Documents and records to keep

• PBO and Section 18A approval letters.
• Donation ledger, bank statements and receipt register.
• Evidence supporting the zero-receipt conclusion.
• Registered-representative details.
• Submitted null declaration and SARS response.

Important limits and exceptions

If even one valid Section 18A receipt was issued, a null declaration is not correct. The entity must submit the relevant receipt data. Receipts issued without authority, duplicated numbers or incomplete donor details need correction, not concealment through a nil submission.

SARS has changed third-party reporting details over time. Confirm the live period and due date before submission instead of relying on a date copied from an older checklist.

When to get tailored advice

Get help if the approval letter is unclear, receipts were issued for mixed qualifying and non-qualifying activities, or the receipt register does not reconcile to the bank and general ledger.

Related TaxProof guides

• Can a company deduct a Section 18A donation?
• How do I enrol for Connect:Direct third-party data?

Sources

• SARS, IT3(d) Third-Party Data FAQs
• SARS, Third-Party Data