The full compliance file for a fuel retailer, wholesaler or energy licensee
A fuel business that can produce its site and retail licences, its current NRCS verification certificates for every dispenser, its SARS excise and VAT registration and, where relevant, its NERSA licence and conditions, has covered the ground that inspectors and auditors actually check.
Reviewed by TefCo Compliance Research — last verified 15 September 2026.
In short
- Licensing, metrology, tax and (for gas/electricity) NERSA compliance are four separate files — they are not consolidated into one certificate.
- Every dispensing pump needs its own current NRCS verification seal, not a single site-wide certificate.
- Diesel refund claimants need a clean audit trail of eligible purchases and use, especially with SARS's move to a standalone Diesel Refund System.
Licensing file
- Current site licence and retail (or wholesale/manufacturing) licence issued under the Petroleum Products Act 120 of 1977.
- Proof of publication of the notice of application, retained from when the licence was first issued or converted.
- Latest annual retail licence information return (DMPR 33) or wholesale/manufacturing equivalent (DMPR 30/37), with proof of submission.
- Any temporary licence documentation, if operating under one.
- Title deed or lease reference for the licensed site, matching the erf/stand details on the licence application.
NRCS legal metrology file
- Current verification certificate and seal for every fuel dispenser on site, issued by an NRCS-designated verification body.
- Records of any repairs to a dispenser and the re-verification that followed, since a repaired instrument must be re-verified before it is used again.
- Registration with the NRCS if the business imports, manufactures or offers prescribed measuring instruments for sale, as required under the Legal Metrology Regulations.
Keep the verification records per pump, not per site — an inspector checks the seal on the specific dispenser in front of them.
SARS excise and levy file
- Excise/customs client registration for excisable products, where the business manufactures, stores or moves excisable fuel.
- Current SARS excise account showing the general fuel levy, carbon fuel levy and RAF levy applied at the correct current rate.
- For diesel refund claimants: registration under the Diesel Refund Scheme (Schedule 6 to the Customs and Excise Act 91 of 1964), logbooks or equivalent records proving eligible use, and monthly or VAT-period claim submissions.
- Correspondence confirming registration status as SARS transitions the Diesel Refund System onto its own standalone platform.
NERSA file (gas and electricity operators only)
- Current NERSA licence for construction or operation of piped-gas facilities (Gas Act 48 of 2001) or generation/transmission/distribution/trading of electricity (Electricity Regulation Act).
- Licence conditions document and any approved amendments.
- Records showing compliance with licence conditions, since NERSA monitors and can enforce against licensees who breach their own conditions.
Site and safety records inspectors also ask for
Underground and aboveground storage tank records, environmental and fire safety compliance, and municipal business licensing sit alongside the above and are usually the first things a joint inspection (DMPR, NRCS, municipal health and fire) asks to see together with the fuel-specific file.
Frequently asked
Does each dispenser need its own NRCS paperwork, or one certificate for the whole forecourt?
Each dispenser is verified and sealed individually, so the compliance file should hold a verification record per pump, not a single site-wide certificate.
Is a diesel refund claim automatic once registered?
No. Claimants must keep records proving eligible use and submit claims each period; SARS is moving this onto a standalone Diesel Refund System separate from the VAT return process [7](https://www.sars.gov.za/customs-and-excise/excise/diesel-refund-system/).
Sources
- South African Government — Petroleum site and retail licence (DMPR)
- Department of Mineral and Petroleum Resources — Petroleum Licensing Resources
- NRCS — Legal Metrology Regulations, GN 877, Government Gazette 41854 (24 August 2018)
- NRCS — Legal Metrology technical regulations (fuel dispensers, R117)
- SARS — Diesel Refund Scheme
- NERSA — Piped-Gas overview and licensing (Gas Act 48 of 2001)
- NERSA — Electricity overview and licensing
TefCo Corporate Compliance (Pty) Ltd is a compliance management platform, not a legal, tax or advisory firm. This guide is general information, not advice. Fees, dates and thresholds change — confirm current figures with the regulator before you rely on them.
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