Companies involved in customs and excise activities operate within a highly regulated environment. Registration and licensing with the South African Revenue Service (“SARS”) is not merely a once-off administrative requirement; it gives rise to an ongoing obligation to ensure that SARS is kept informed of any material changes to the information originally provided during the registration or licensing process.

Sections 59A and 60 of the Customs and Excise Act 91 of 1964 (“the Act”) establish the framework for the registration and licensing of persons engaged in activities regulated by the Act and empower the Commissioner to prescribe procedures for amending registered particulars.

Failure to notify SARS of relevant changes may expose a business to significant operational and compliance risks, including the suspension or cancellation of registrations or licences, delays in customs clearances, and increased regulatory scrutiny.

As a general principle, any change affecting information previously furnished to SARS should be disclosed. Examples of changes that should be reported include:

• Registered name;
• Trading name;
• Business address;
• Directorship;
• Stockholding;
• Legal status of the business; and
• Contact details, including telephone numbers.

From a corporate governance perspective, businesses should implement appropriate internal controls to ensure that changes affecting their customs registrations and licences are identified and reported promptly. Good practice measures include:

• Reviewing registration and licence particulars following any corporate restructuring or organisational change;
• Conducting periodic compliance reviews; and
• Maintaining supporting documentation in a readily accessible format for submission to SARS when required.

Maintaining accurate and up-to-date information with SARS is essential to preserving registration and licensing status, safeguarding customs privileges, and facilitating the efficient movement of goods. Businesses that adopt a proactive approach to compliance will be better positioned to minimise regulatory risk and ensure uninterrupted participation in international trade.