What's changed for NPOs, PBOs and trusts

Three connected changes reshaped this sector after South Africa's 2023 FATF grey-listing response. The General Laws (Anti-Money Laundering and Combating Terrorism Financing) Amendment Act 22 of 2022 amended both the Nonprofit Organisations Act and the Trust Property Control Act, the Master opened an ongoing beneficial ownership register for trusts from April 2023, and SARS has now tightened what a section 18A donation receipt must contain from 1 March 2026.

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

In short

The General Laws (Anti-Money Laundering and Combating Terrorism Financing) Amendment Act 22 of 2022 amended both the Nonprofit Organisations Act 71 of 1997 and the Trust Property Control Act 57 of 1988.
Trustees have had to lodge and maintain beneficial ownership information with the Master since 1 April 2023.
SARS Notice 6762 prescribes additional mandatory information on section 18A receipts issued from 1 March 2026.
The FIC issued guidance in November 2023 on how the amended beneficial ownership obligations apply to accountable institutions dealing with trusts.

The General Laws Amendment Act: what it changed for NPOs

The General Laws (Anti-Money Laundering and Combating Terrorism Financing) Amendment Act 22 of 2022 amended the Nonprofit Organisations Act 71 of 1997 to require registration of specified nonprofit organisations, to let the NPO Directorate collaborate and co-ordinate with other organs of state, to clarify the Director's powers over registration, cancellation and amendments to an NPO's constitution, and to expand reporting requirements for registered NPOs.

Regulations giving effect to these changes were published by the Department of Social Development in May 2023, covering a disqualified office-bearers register, powers of the Directorate, fiscal sponsorship, and administrative penalties.

What it changed for trusts

The same Act inserted definitions of 'accountable institution' and 'beneficial owner' into the Trust Property Control Act 57 of 1988, imposed new record-keeping requirements on trustees, set out grounds that disqualify a person from acting as trustee, and required the Master to establish and maintain a beneficial ownership register with defined access rules. It also created new offences for non-compliance.

With effect from 1 April 2023, trustees became obliged to lodge beneficial ownership data through the Master's online portal and to keep it up to date — this is an ongoing obligation that follows every change of trustee or beneficiary, not a once-off registration event.

The Financial Intelligence Centre's public compliance communication on beneficial ownership, issued in draft in November 2023, is aimed at accountable institutions (banks, trust and company service providers) verifying trust clients — it does not replace the trustee's own duty to the Master, it sits alongside it.

Section 18A receipts: new mandatory fields from 1 March 2026

SARS Notice 6762 prescribes additional information that must appear on section 18A donation receipts issued on or after 1 March 2026, replacing the format that had applied since 2023. The expanded fields cover the donor's type (natural person, company or trust), ID type and country of issue, company or trust registration number, trading name if different from the registered name, income tax reference number, contact number and email address, plus a unique receipt number and, for donations in kind, a description of the property and its deemed deduction value.

Organisations issuing section 18A receipts should update their receipt templates and donor-capture processes ahead of the effective date rather than after it, since a non-compliant receipt puts the donor's deduction at risk.

Frequently asked

Did NPO reporting deadlines themselves change under the General Laws Amendment Act?

The Act expanded what registered NPOs must submit and strengthened the Directorate's powers, rather than changing the underlying six-month/two-month timing in section 17 of the Nonprofit Organisations Act 71 of 1997. Confirm current DSD guidance for any procedural timing changes made under the 2023 regulations.

Is beneficial ownership reporting for trusts a single once-off filing?

No — it is an ongoing duty. Trustees must keep the register up to date whenever beneficial owners, trustees or control arrangements change.

Do the new section 18A rules affect receipts already issued before March 2026?

The notice's additional requirements apply to receipts issued from 1 March 2026. Confirm with SARS how it treats receipts issued earlier if a donor query arises.

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.