A legal entity cannot act on its own, so SARS records a natural person as its SARS registered representative. For a company, this is commonly the public officer. If the representative is missing, deceased, resigned or not verified, eFiling access, registrations and correspondence can be delayed even when a practitioner has a mandate.

What the SARS registered representative does

The SARS registered representative is the person SARS recognises as having authority to act for the entity. A tax practitioner can perform authorised work, but the entity still needs a valid representative.

For the current official requirements, refer to SARS’s registered-representative guidance and SARS’s client-information guidance.

For a trust, the representative is commonly a main trustee appointed by trustee resolution.

Why profiles become blocked

• The former director or trustee is still recorded
• The public officer was never formally appointed
• CIPC and SARS details do not match
• The representative’s identity, contact or address documents are outdated
• The entity has duplicate tax references or profiles
• The person attempting the update lacks authority
• A practitioner mandate is confused with representative status

Update channels

SARS states that registration or update of a registered representative can be done through eFiling or the SARS Online Query System, with branch assistance by appointment where needed.

The correct channel depends on profile access and the supporting documents available.

Documents commonly required

• Representative’s identity document
• Entity registration documents
• Board or trustee resolution appointing the representative
• Proof of the entity’s address
• Proof of the representative’s residential address
• CIPC disclosure or Letters of Authority
• Authority or mandate for the practitioner
• Additional documents requested for the entity type

Public officer changes after a director change

Updating CIPC does not automatically update SARS. Where a director who served as public officer resigns, appoint the replacement formally and complete the separate SARS process.

Banking, customs, VAT, PAYE and tax-compliance work may depend on the update.

Security and access control

The registered representative should not hand over personal eFiling passwords. Practitioner and staff access should be granted through formal portfolio and authorisation functions.

Review access whenever directors, trustees, employees or advisers change.

A practical resolution process

• Confirm the entity’s current CIPC or Master records
• Identify the person with lawful authority
• Prepare the appointment resolution
• Compile identity and address evidence
• Submit through the appropriate SARS channel
• Track the case number and respond to requests
• Confirm tax types and user permissions after activation

Example: former accountant controls the profile

A company believes its accountant is the public officer, but the SARS record still reflects a director who left years ago. The practitioner may have access to submit some returns while the entity cannot make profile changes. The solution is a lawful representative appointment and SARS verification, not password sharing.

Keep an authority register

Record the current CIPC directors, public officer, SARS registered representative, trustees, bank signatories and authorised advisers. Review the register after every governance change.

Related LMW guidance covers VAT registration, provisional tax and IRP6 returns, and ITR14 company income-tax returns.

How LMW Financial Solutions can assist

LMW can review the profile problem, prepare routine appointment documents, compile the supporting pack and assist with the SARS update and follow-on tax access.

Need practical assistance?
Request a quote from LMW Financial Solutions for practical assistance with this matter. Request a Quote

Frequently Asked Questions

Is a tax practitioner the same as a SARS registered representative?

No. A practitioner acts under authority, while the registered representative is the natural person SARS recognises as representing the entity.

Can I update a SARS registered representative online?

SARS provides eFiling and SARS Online Query System routes, subject to access and document requirements.

Does CIPC update SARS automatically?

No. The SARS registered representative or public officer process is separate.

Who is the registered representative of a trust?

It is commonly a main trustee appointed by a trustee resolution and accepted by SARS.