What changes when a company's public officer leaves the business?

Treat the departure as a tax-governance handover

A public officer's departure is more than removing an employee from the contact list. Establish the date the person ceases to act, who will take responsibility and how the company will continue receiving and responding to SARS communications. Keep this process connected to the personnel change, but do not assume the personnel system updates the tax record.

Current SARS guidance on company representation says the relevant public-officer position must remain filled and changes to the officer or notice address must be reported within 21 business days. Treat the notification deadline separately from the requirement for continuing representation.

Older material may mention a month to appoint the first public officer. Act 43 of 2024 removed that wording. Do not use an old checklist as a grace period for an unplanned vacancy. Identify the current legal and administrative steps promptly and record who will complete each one.

Confirm an eligible successor and the authority to appoint

Discuss the replacement before focusing on portal access. Current requirements concern a suitable individual residing in South Africa and the appropriate senior-official position, with the alternative route subject to its conditions. Someone who happens to know the company password is not thereby an eligible public officer.

Record the company's appointment decision and obtain the relevant acceptance and supporting documents. Check the actual circumstances rather than automatically naming the external accountant. A tax practitioner can assist the company without every assistance arrangement making that person the public officer.

Where directors disagree, the outgoing person is unavailable or the company has unusual governance circumstances, obtain advice on the appointment itself. Access recovery cannot repair a defective or disputed mandate. Keep the decision and its effective date in the company records so the SARS update and internal handover describe the same change.

Update and verify the SARS representative record

Use the current SARS registered-representative process and the requirements for the company and channel. Prepare the entity and identity records, appointment evidence and other material the case requires. Check the exact names and references before submission.

Save the request reference and any acknowledgement, then track requests for further documents. A lodged update is not the same as a completed change. After processing, read back the representative and contact information and confirm that the right person can act for the correct company.

SARS's profile-activation guidance explains that a new registered-representative activation can affect the previous representative's access. Plan the handover with that effect in mind. Do not depend on the outgoing person's access continuing indefinitely while the successor tries to locate old returns.

Create an open-work register before the person leaves

Ask for a register of current tax work, not just a list of reference numbers. Include each tax type, period, status, next action, due date and responsible person. Reconcile the register with actual SARS correspondence and account records so it captures work that may have remained in the outgoing person's inbox.

Separate confirmed status from assumptions. For example, a return marked prepared may never have been submitted, and a payment marked sent may still have an allocation issue. The new officer should know which statements are supported by records and which require a check.

Transfer the evidence that explains prior decisions

Preserve final returns, assessments, financial statements, tax calculations and relevant correspondence in an organised company record. Include the workings behind unresolved matters, so the successor does not have to guess why a figure was used or what SARS was told.

• Identify the financial periods covered by each file.
• Keep final versions separate from superseded drafts.
• Explain significant adjustments and outstanding assumptions.
• Record where original supporting documents are held.
• Provide the names and roles of external advisers handling specific matters.

Check that the files can actually be opened by the people authorised to use them. A link to an outgoing employee's private storage may stop working after departure. Choose an appropriate company-controlled record arrangement and transfer the necessary files through the agreed process. The goal is continuity of evidence, with personal information available only to those who need it for the authorised work.

Review access independently of document handover

Make an inventory of the organisation profile, relevant tax types, authorised users and practitioner relationships. Determine which permissions the successor requires and which departing access should end. Distinguish the company record from the outgoing person's personal eFiling profile and credentials.

Do not ask the successor to impersonate the outgoing person. Use the appropriate representative, organisation and practitioner processes so actions are carried out under proper authority. Once the new arrangements work, confirm the removal or change of access that is no longer authorised.

Check contact and recovery information as well as ordinary login access. An otherwise successful handover can fail if important notices or verification requests still reach a person who has left. Record the test results and remaining gaps without collecting or circulating personal passwords or one-time codes in the handover file.

A handover example with an open verification

Consider a company whose finance director is leaving while a VAT verification request is open. The outgoing officer has uploaded some documents, the bookkeeper holds the invoices and an external practitioner is preparing the remaining explanation. Appointing a successor alone would not tell that person what still needs to happen.

The handover register should identify the request, the documents already submitted, the outstanding explanation, the actual response date and the person authorised to complete it. The successor should be able to locate the uploaded evidence and understand the practitioner's role. The company should also confirm where further messages will arrive after the representative change.

This fictional example shows why authority, access and work status need separate checks. A successful login does not prove the verification response is complete. An email from the practitioner saying documents are ready does not prove they were submitted. Keep the evidence for each step so the new officer can take responsibility with a clear view of the remaining work.

If the departure was sudden or disputed

Start with company records and the official update or assistance channels rather than waiting for the former officer to return a password. Identify the company's authorised decision-makers, the existing tax references and the immediate obligations. Gather evidence of the appointment and the circumstances preventing a normal handover.

Prioritise notices and deadlines that need action now. Tell the authorised adviser which documents are unavailable and which facts remain uncertain. Do not mark an obligation complete because no one can find the file. Recover the submission or account evidence through the proper channel where possible.

Keep a contemporaneous action log with request references, dates and responses. If an authority dispute affects who may act, resolve that issue with appropriate advice instead of attempting repeated profile changes under competing names. Administrative urgency does not establish a person's mandate.

Confirm what the change does and does not resolve

A representative update changes who acts for the company; it does not settle every historical tax issue. Keep outstanding returns, debts, information requests and agreed actions visible until they are individually resolved. Similarly, a CIPC director change and a SARS representative change should each be checked against their own records.

Public-officer activation support can help organise the documents and administrative steps. Close the handover only after the successor can perform the required functions, the company can receive notices and the open-work register has clear owners. Retain that confirmation with the appointment record and review any unresolved item at the next tax-administration check.