Everything a motor dealer or panelbeater must have on file

A motor dealer or panelbeater that can produce its Second-Hand Goods Act certificate, motor trade number registration, MIBCO returns history, NRCS Letters of Authority for any imported or rebuilt stock, and its own vehicle purchase and sale registers is in a defensible position with SAPS, MIBCO and NRCS alike.

Reviewed by TefCo Compliance Research — last verified 15 September 2026.

In short

The Second-Hand Goods Act register of transactions is a distinct, mandatory record from ordinary bookkeeping.
A motor trade number is separate from Second-Hand Goods Act registration and from MIBCO membership — check all three, not just one.
Any vehicle imported, built or modified for registration needs its own NRCS Letter of Authority on file before it is sold or licensed.

Second-Hand Goods Act file

Current certificate of registration as a dealer or recycler, displayed as required by the Act.
Renewal application (Form SAPS 601(e)) lodged before the certificate's expiry date, with proof of lodgement.
Records of second-hand goods transactions kept as prescribed — description of goods, price, and identity details of the person the dealer is transacting with.
Motor vehicle records required under Chapter 5 of the Second-Hand Goods Act 6 of 2009 for any vehicles bought, sold or otherwise handled.
Notification of any change of business information (Form SAPS 604) filed promptly.

Motor trade number and vehicle movement file

Motor trade number (MTN) certificate obtained via Form MTN1 under the National Road Traffic Act 93 of 1996.
Log of blank temporary permits issued and used against the MTN.
NRCS Letter of Authority for every vehicle type imported, built or modified before registration and licensing.
Proof of NRCS fee payment attached to each Letter of Authority application.

NRCS notes its own turnaround can run up to 120 calendar days for a Letter of Authority. Build that lead time into any import or build programme rather than applying once a vehicle has already landed.

MIBCO and labour file (where the business falls under the Main Agreement)

MIBCO employer registration and employer code.
Monthly returns filed and reconciled, due on the 10th of each month.
Proof of council levy deductions and payments for covered employees.
Any MIBCO wage exemption approval, if the business is trading on exempted terms rather than the standard Main Agreement rates.

Frequently asked

Does a sole trader panelbeater need a motor trade number?

Only if the business needs to operate vehicles on public roads that are not yet registered or licensed — for example moving stock for testing or delivery. Confirm the specific circumstances against the National Road Traffic Act 93 of 1996 and the relevant registering authority.

Is an NRCS Letter of Authority needed for a vehicle bought already registered in South Africa?

No — the Letter of Authority requirement applies to importing, building or modifying a vehicle before it is first registered and licensed, not to buying and reselling an already-registered vehicle.

Sources

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.