Does PBO approval automatically allow section 18A donation receipts?

Find the specific section 18A approval

Start with the actual SARS letter. Find the paragraph confirming section 18A approval and the associated reference. Do not infer that approval from a general reference to income tax exemption. If the organisation has several letters, arrange them by date and identify whether a later decision changes the earlier position.

The SARS section 18A guide explains the distinction between PBO approval and donation-receipt authority. A combined application can produce both approvals, but selecting one status does not automatically establish the other.

Keep a readable copy where the people responsible for fundraising and finance can consult it. Record who checked the letter and when. A staff member should not have to rely on an old website sentence or a donor’s assumption when deciding which receipt to issue.

Check both the organisation and the transaction

These checks work together. A correct reference number cannot transform an ineligible transaction into a deductible donation. Equally, a genuine gift to a worthwhile project does not itself establish the recipient’s authority to issue a section 18A receipt.

Match the funds to the qualifying purpose

Review which public benefit activities are covered by the applicable section 18A provisions and the organisation’s approval. The PBO framework and section 18A framework do not have identical reach. A programme can serve a public purpose while still needing separate examination before it supports a deductible receipt.

Where the organisation carries on several programmes, identify the intended use of each donation. Keep restrictions in donor agreements visible to finance staff. If funds are accepted for a programme outside the relevant approval, do not simply allocate them to another project on paper to justify issuing the requested receipt.

For mixed activities, obtain advice about the required separation of funds and records. A practical project code can help trace income and spending, but it does not replace any substantive condition. The board should understand which programmes can receive donations under the approval and who checks changes before fundraising begins.

Distinguish a donation from a purchase

Read the agreement before deciding how to describe a payment. A gift, a ticket purchase, sponsorship with commercial benefits and a service contract can create different questions. The words “donation” in a bank reference do not settle the legal character of the transaction.

For example, a fictional business pays a charity for a package that includes advertising and attendance places. Finance should inspect what was promised and delivered. It should not automatically issue a section 18A receipt for the whole payment merely because the charity uses the proceeds for a good cause.

Ask the fundraiser for the proposal, correspondence and benefit schedule, not only the deposit confirmation. If there are genuinely separate elements, obtain an appropriate assessment of their treatment and retain the reasoning. Avoid inventing a split after the event solely to meet the payer’s preferred tax outcome.

Property donated in kind requires its own review. Record what was transferred, by whom and when, together with evidence of the property. Do not choose a receipt value from an unsupported donor estimate or assume that the rules for money and property are identical.

Handle pending applications and old donations honestly

If section 18A approval is still pending, describe that status accurately. The SARS guide distinguishes approval from an application and links receipt authority to confirmed approval. Do not promise that a later decision will automatically make every earlier donation eligible.

Check the actual decision and applicable rules before dealing with donations near the approval date. Preserve the original payment date and correspondence. Changing a receipt date to conceal when funds were received does not solve an approval problem.

An organisation may acknowledge receipt of funds without representing the document as a section 18A tax receipt. Use clear wording and keep that acknowledgement distinct from a later tax document, if one is lawfully appropriate. Communicate the uncertainty before a donor relies on an unsupported promise.

Apply separately when an existing PBO lacks approval

The SARS FAQ updated in April 2026 directs an existing PBO to the RAVTEI application through eFiling or a SARS branch. Check the current route rather than relying on older guides that describe a written request or an earlier form.

Confirm that the entity’s recorded legal nature matches its founding document. SARS identifies particular historic entity descriptions that need correction before an application can proceed. The current exemption application guidance helps establish the records required.

Prepare an explanation of the activities for which approval is requested, the governing document and relevant financial evidence. Save the submission and questions received. Approval remains a SARS decision; an urgent fundraising campaign does not substitute for meeting the conditions.

Update the receipt process for current requirements

The current SARS receipt and IT3(d) page identifies additional receipt-information requirements effective from 1 March 2026 under Notice 6762. Review the applicable notice and current rulings before reusing an old template.

Assign responsibility for collecting donor information, checking the transaction, issuing the receipt and correcting errors. Use controlled receipt references and keep a record of replacements so that one donation is not unintentionally represented by two active receipts.

1. Confirm the organisation’s approval and the covered activity.
2. Review the actual donation and supporting agreement.
3. Collect the prescribed donor and transaction information.
4. Check the receipt against current requirements.
5. Save the issued version with the underlying evidence.
6. Include the record in the reporting and reconciliation process.

If a receipt has already been issued incorrectly, stop copying the same error into further receipts. Identify the affected document, original transaction and information sent to SARS. Ask the responsible adviser which correction and reporting steps apply. Contact the donor with a clear explanation of the corrected position through the organisation’s authorised process. Keep the original and replacement linked in the internal register, with the reason and approval for the change. Quietly deleting the original record would make it harder to establish what the donor received and whether the reporting data still contains the error.

Do not circulate donor records more widely than necessary. Staff arranging an event may need confirmation that a receipt was issued without needing unrestricted access to every donor’s personal tax details.

Keep receipt records connected to reporting

Section 18A-approved organisations have IT3(d) reporting responsibilities. SARS explains that uploading data alone is not completion: the IT3-02 declaration is also required. It also provides for a null declaration where an approved organisation issued no section 18A receipts for the period.

Reconcile the receipt register to donation records and explain cancellations or corrections. Keep reporting acknowledgements with the period’s working papers. The August 2026 SARS update reinforces these continuing obligations.

A donor’s eventual deduction remains subject to the donor’s own tax circumstances and applicable limits. The charity should provide an accurate compliant receipt, rather than guarantee the donor’s assessment outcome.

Prepare a focused approval or receipt enquiry

For PBO registration and approval support, provide the SARS letters, founding document, activities and the particular transaction causing uncertainty. State whether the problem is missing approval, unclear scope, a proposed receipt or reporting.

Use the NPC and PBO distinction guide if the organisation has only recently formed. Getting the status and transaction right before issuing a receipt reduces the need to correct donor expectations later.