SARS IT3(BO): What South African Partnerships Must Do Now to Stay Compliant in 2026

Miss This SARS Submission and Your Partners Cannot File Their Tax Returns

If your business operates as a partnership in South Africa, a new annual SARS submission now stands between your partners and their ability to file their individual income tax returns. SARS has launched the Beneficial Owner Register for Partnership — the IT3(BO) form — and if your designated partnership representative does not submit it on eFiling, every partner in the business is blocked from completing their ITR12 correctly. That is not a theoretical risk. It is the design of the new system.

What SARS Has Changed and Why

The requirement to disclose beneficial ownership in partnerships is not new. It traces back to the General Laws (Anti-Money Laundering and Combating Terrorism Financing) Amendment Act 22 of 2022, which compelled SARS to collect partner details as part of South Africa's anti-money laundering framework.

During the 2024 Filing Season, SARS implemented this by requiring each partner to declare the details of every other partner — excluding themselves — directly on their own ITR12. The problem was immediately obvious: a five-partner firm generated five separate, overlapping sets of partner disclosures, each slightly different, each prone to error. The administrative burden was significant and the data quality was poor.

SARS has now corrected this with a single centralised form. As of 22 April 2026, SARS confirmed the launch of the IT3(BO) on eFiling. The concept is straightforward: one person submits all partner information once, SARS issues a unique reference number, and every partner uses only that number on their ITR12. The duplication is gone. The compliance obligation, however, is very much still there — and it now rests squarely on the shoulders of whoever the partnership nominates as its representative.

Exactly How the IT3(BO) Process Works

The process runs in three steps and the sequence matters.

Step one — nominate and submit. The partnership must nominate a designated representative. That person accesses the IT3(BO) form on SARS eFiling, captures the details of all partners, and submits the completed form to SARS. No other partner needs to do this. One submission covers the entire partnership.

Step two — SARS issues the IT3(BO) unique number. After processing the submission, SARS issues a Beneficial Owner Register for Partnership Notice (IT3[BO]) to the appointed representative. This notice contains the IT3(BO) unique number for the partnership. The representative uses this same unique number in future years to retrieve previously submitted details, make updates, and resubmit.

Step three — partners receive notification and use the number. SARS separately issues a Beneficial Owner Partner in a Partnership Notice to each individual partner. This notice also contains the IT3(BO) unique number. Each partner then uses only this number — not the full partner details — when declaring partnership information on their annual ITR12.

The critical detail: the IT3(BO) form must be submitted annually by the designated representative. This is not a once-off registration. Miss a year and the unique number becomes stale, partners cannot reference it accurately, and ITR12 submissions for the entire partnership are compromised.

Who Is Affected

Any business structured as a partnership under South African law is affected. This includes professional partnerships — attorneys, accountants, architects, engineers, medical practices, and consulting firms — as well as trading partnerships and family business arrangements that have not incorporated. If two or more people share profit and loss from a business without a registered company or close corporation sitting between them, they are almost certainly in a partnership for tax purposes.

The obligation sits primarily with the designated partnership representative. If your partnership has not yet nominated someone for this role, that is the first problem to solve. The representative must have eFiling access and must understand that they carry an annual filing obligation on behalf of the entire partnership — not just themselves.

Individual partners are affected indirectly but critically: without the IT3(BO) unique number issued after the representative's submission, they cannot correctly complete the partnership declaration section of their ITR12.

The Consequences of Getting This Wrong

SARS's stated position is unambiguous: make non-compliance hard and costly. While SARS has not published a specific penalty schedule exclusively for IT3(BO) non-submission in the source material available, the downstream consequences are clear and serious.

If the designated representative fails to submit the IT3(BO) form, no unique number is generated. Without the unique number, partners cannot accurately complete their ITR12. An ITR12 filed without the required partnership disclosure is incomplete and exposes the partner to administrative penalties under the Tax Administration Act. SARS has broad powers to levy penalties of R250 to R16,000 per month for non-compliant returns, depending on taxable income — and these penalties accumulate monthly until the deficiency is corrected.

Beyond penalties, a partner whose ITR12 is flagged as incomplete may find their Tax Compliance Status (TCS) affected. A non-compliant TCS has real commercial consequences: it blocks access to foreign investment allowances, complicates tenders and government contracts, and can prevent the issuance of a Tax Clearance Certificate. For professional partnerships that depend on public-sector work, this is an existential operational risk.

The anti-money laundering context of this requirement also matters. The General Laws Amendment Act 22 of 2022 carries its own enforcement mechanisms. Failure to disclose beneficial ownership accurately is not treated by regulators as a filing technicality — it is treated as a transparency failure, and regulators have shown willingness to act accordingly.

What Your Partnership Must Do Right Now

The steps are specific and the order matters.

First, confirm whether your business is legally structured as a partnership. If you share profits with one or more people and have no registered company or close corporation, you are almost certainly a partnership. If you are unsure, ask your accountant before the next filing season opens.

Second, nominate a designated partnership representative. This person must have an active SARS eFiling profile. The nomination should be documented internally — even a simple written resolution naming the representative protects the partnership if the question ever arises.

Third, access the IT3(BO) form on SARS eFiling. The representative logs in, locates the IT3(BO) form, and captures the details of all partners accurately. Errors here flow through to every partner's ITR12, so accuracy at this stage matters.

Fourth, obtain and distribute the IT3(BO) unique number. Once SARS processes the submission and issues the notice, the representative must share the unique number with all partners so they can reference it correctly on their individual ITR12s. Do not assume SARS's partner notification is sufficient — confirm directly with each partner that they have received and noted the number.

Fifth, calendar the annual resubmission. The IT3(BO) is not a once-off task. Set a recurring reminder for the representative to log in, retrieve the existing submission using the unique number, update any changes to the partner composition or details, and resubmit before each filing season.

Sixth, check your own Tax Compliance Status on SARS eFiling. Each partner should log into their individual eFiling profile and verify their TCS is active and green before the filing season deadline. Do not wait for SARS to flag a problem — check proactively.

For more detail on the submission process, SARS has published the IT-AE-36-G07 — Guide to the Beneficial Owner Register for Partnership IT3BO Form, available on the SARS website.

One More Compliance Layer Partnerships Often Miss

The IT3(BO) requirement sits alongside — not instead of — the Companies and Intellectual Property Commission's (CIPC) beneficial ownership obligations. If your partnership has converted to a private company or operates through a company structure, that company has separate beneficial ownership disclosure obligations at CIPC, including annual return filings and company status maintenance.

These are distinct obligations managed by different regulators. Staying on top of both is the baseline for operating a compliant business in South Africa in 2026.

Get Connected to an Accountant Who Handles This

ClearComply reads CIPC records — beneficial ownership filings, annual returns, and company status. For SARS matters, including the IT3(BO), ITR12 filings, and tax compliance status, you need a registered tax practitioner or accountant who works in this space daily.

If you are not sure where to start or who to call, tell us what you need and we will connect you with the right person. Visit clearcomply.co.za/help/vat and let us know — we will put you in touch with an accountant who handles SARS partnership compliance. No runaround. Just the right contact.