South Africa’s tax authorities are poised to gain unprecedented visibility into the offshore financial holdings of its citizens, effective March 1, 2026, as the country fully adopts the Organisation for Economic Cooperation and Development’s (OECD) Crypto-Asset Reporting Framework (CARF) and a revised Common Reporting Standard (CRS).
The move, confirmed by the National Treasury and the South African Revenue Service (SARS), extends automatic exchange of information (AEOI) to encompass digital assets, significantly broadening the scope of financial transparency. More than 70 jurisdictions globally are implementing similar standards between 2026 and 2027, according to the OECD, creating a coordinated global reporting architecture.
Under the new regime, financial institutions in over 120 countries will be compelled to routinely share taxpayer information with SARS, detailing assets and income held by South African residents. This systematic transmission of “bulk” taxpayer information aims to ensure accurate tax reporting and curb tax evasion.
The implementation of CARF is particularly significant, extending AEOI into the digital asset economy. This impacts not only traditional banks and exchanges but also custodial wallet providers and fintech platforms, transforming compliance from a traditional account-based model to one focused on digital asset transparency. The CARF XML Schema, as defined by SARS, requires a specific wrapper to be added to the standard OECD XML schema for domestic reporting purposes.
Tax experts at Tax Consulting SA emphasize that this isn’t a new power for SARS, which has long been able to request taxpayer information from third parties under the Tax Administration Act, particularly when guided by international tax agreements. However, the AEOI regime dramatically enhances SARS’s enforcement capabilities and access to data.
“Whereas the automatic exchange may be a foreign concept to South African taxpayers, SARS has been able to request taxpayer information from third parties for many years,” the firm noted in a recent analysis. They also point to previous initiatives, such as offshore asset/income disclosure notices issued as far back as 2020, as evidence of SARS’s long-standing focus on offshore holdings.
The shift signifies a more aggressive stance from SARS, a trend highlighted by analysts observing recent budget revisions. Finance Minister Enoch Godongwana recently revised the 2025/26 revenue estimate upward to R2,006.9 billion. SARS Commissioner Edward Kieswetter, who is set to retire in April 2026, has publicly stated the revenue service will “spare no effort” to achieve this estimate, with a specific focus on increasing compliance revenue.
Compliance revenue has turn into a key driver of SARS’s performance, increasing from R128.4 billion in 2019/20 to R304.0 billion in 2024/25 – a compound annual growth rate of 18.8%. Tax Consulting SA warns that this trend is likely to intensify, with taxpayers facing increased audits, and pressure. SARS has already demonstrated its willingness to utilize aggressive collection methods, including salary garnishments and direct account levies.
Tax Consulting SA asserts that SARS will not accept claims of ignorance as a defense against non-compliance. The firm emphasizes that the burden of proof remains firmly on the taxpayer to substantiate foreign income, capital gains, and source of funds.
The implementation of CARF and CRS 2.0 aligns South Africa with a growing international movement aimed at preventing regulatory arbitrage and protecting domestic tax revenues. By enabling information exchange with foreign authorities, SARS aims to ensure that digital asset activity is no longer shielded from tax scrutiny.
