Can I issue VAT invoices while registration is pending?

Direct answer

No, not a VAT tax invoice under section 20 while registration remains unconfirmed. SARS states that section 20 requires a registered vendor. Once registration is confirmed, issue the tax invoices that would have been required for taxable supplies from the accepted liability date as soon as possible.

A compulsory applicant may still need to charge and collect VAT from the liability date while confirmation is pending. The price from that date is generally treated as VAT-inclusive, subject to the detailed time-of-supply and contract rules.

What this means in practice

Use a commercial invoice that does not misrepresent the business as already registered. Explain to customers that the final tax invoice will follow after SARS confirms the number and liability date. A vendor customer normally needs that valid tax invoice before deducting input tax.

From 1 April 2026, SARS administers a R2.3 million compulsory threshold and R120,000 voluntary threshold, subject to the announced legislative process and exceptions.

Step-by-step

1. Determine whether registration is compulsory or voluntary.
2. Establish and document the correct liability date.
3. Apply within the required period with complete evidence.
4. Price taxable supplies on the correct VAT-inclusive basis.
5. Avoid calling a document a tax invoice before confirmation.
6. After approval, issue compliant tax invoices promptly and reconcile output tax.

Documents and records to keep

• VAT application and supporting contracts.
• Turnover calculation and liability-date evidence.
• Interim commercial invoices.
• VAT notice of registration.
• Replacement tax invoices and VAT201 reconciliation.

Important limits and exceptions

Voluntary applicants are not vendors until confirmation, while compulsory liability can arise earlier. Existing contracts and sections 67 and 67A can change the amount or timing.

When to get tailored advice

Get advice when the application is backdated, contracts quote VAT-exclusive prices or customers demand immediate tax invoices.

Related TaxProof guides

• What details must appear on a full VAT invoice?
• How do I cancel a VAT registration?

Sources

• SARS, VAT Connect Issue 20
• SARS, Register for VAT