Staying registered as a tax practitioner
What a South African tax practitioner registered through SAICA submits at first registration and each year: compliance PIN, criminal record, declaration.
By Achekam · · 4 min read · For Accountants & audit firms in South Africa
Getting registered as a tax practitioner is one hurdle; staying registered is a yearly one. For a SAICA member, that means a declaration every year, an affidavit every few years and a clean tax record of their own, and each of those competes with every client deadline for the practitioner's attention.
A practice with several registered practitioners needs to know, for each of them, what is due and when, because a lapsed registration affects what that person may do for clients. This article sets out what SAICA asks for at first registration and each year after, and how a practice can keep its own record of where each person stands.
At first registration
SAICA says first-time tax practitioner applicants must submit:
- a valid tax compliance status PIN, or a screenshot of their compliance dashboard;
- an independently verified criminal record certificate.
Both take time to obtain. The criminal record certificate in particular depends on a process outside the applicant's control, so start it well before the application is due. For the wider registration requirements, including who must register at all, see who must register as a tax practitioner.
Every year: the annual declaration
SAICA says its tax practitioner members must submit an annual declaration on the SAICA Member Portal covering:
- their continuing professional development;
- their compliance with SAICA's code of ethics;
- any criminal convictions for offences under section 240(3) of the Tax Administration Act.
The declaration is personal, and each answer in it is the practitioner's own statement to their controlling body. A practice cannot make it on behalf of its staff, but it can make sure each practitioner knows it is due and has what they need to complete it, especially the CPD record. The CPD requirements themselves are covered in CPD hours for SAICA tax practitioners.
Every five years: the affidavit
SAICA says registered practitioners must submit a sworn affidavit on their criminal status every five years. It is easy to forget something that comes round so rarely, so record the date each practitioner last submitted it and when the next one falls due.
The practitioner's own tax compliance
SAICA also says it verifies each practitioner's tax compliance status once a year at renewal. A tax practitioner whose own affairs are not in order is a problem for their registration as well as for their personal tax.
SARS says that to be tax compliant, a taxpayer must have no outstanding returns, no outstanding tax debt unless a payment arrangement or suspension is agreed, registration for every tax they are liable for, and up-to-date registered particulars. SARS also says a compliance status is not static: it changes with continued compliance, and taxpayers can view it through My Compliance Profile on eFiling.
The practical lesson is that practitioners should check their own profile well before renewal, with the same routine they apply to clients. Busy practitioners file clients' returns first and their own last; the renewal check is where that habit catches up with them.
Disqualifications that end a registration
SARS says a person may not register, or remain registered, as a tax practitioner if, in the preceding five years, they were removed from a profession for serious misconduct, or were convicted of a dishonesty offence or a serious tax offence. Such a person may reapply only after five years.
The annual declaration's question on convictions is therefore not a formality. A practice that learns that one of its practitioners has been convicted of a relevant offence, or removed from a profession, needs to deal with what that person may do for clients straight away.
What Achekam records, and what it does not check
Achekam keeps a register of practitioner credentials under TEAM > Practitioner Credentials. A partner, manager or administrator records each practitioner's professional body, their membership standing with the date it was verified, and their practising authority, with evidence. A credential that someone recorded about themself is flagged, so a self-declared entry stands out from one a colleague verified.
That register is a good home for the dates this article describes. For each tax practitioner, record the SAICA membership standing and when it was verified, the date of the last annual declaration, the date of the last five-yearly affidavit, and the date the practitioner's own compliance status was last checked.
The limit needs stating plainly. For a South African firm, Achekam does not check the practitioner credentials register when a partner approves an audit report or signs financial statements; signing needs only the Partner role. Nigerian and Kenyan packs do block signing on unverified registrations, but the South African pack does not. The register is the practice's record, and keeping it current, and acting on it, is the practice's job.
A yearly routine for the practice
| When | What | Who |
|---|---|---|
| Well before renewal | Each practitioner checks their own compliance profile | The practitioner |
| Before the declaration | CPD record complete and evidence filed | The practitioner, checked by a manager |
| At declaration | Annual declaration submitted on the SAICA portal | The practitioner |
| After declaration | Date recorded in the credentials register, with evidence | A partner, manager or administrator |
| Every five years | Affidavit on criminal status submitted | The practitioner |
SAICA's page on the obligations
SAICA's page on tax practitioner obligations sets out what members registered as tax practitioners must do, including the annual declaration and CPD. Share it with every practitioner in the practice, and fill in the credentials register with each person's dates before the next renewal opens.
General guidance only, not advice on your own circumstances. Tax and payroll rules change: check the current position with the authority or your adviser.
