When you register a company, trust, or other entity with SARS, SARS needs to know who the human being is that they can legally hold responsible for that entity’s tax affairs.

That person is called the Registered Representative (RR).

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In simple terms:

A Registered Representative is the person SARS legally recognises as being responsible for a business’s tax compliance.

SARS does not deal with “companies” in the abstract — it deals with people who act on behalf of those companies.

What Does a Registered Representative Do?

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The RR is not responsible for doing the accounting or submitting returns themselves, but they are legally accountable for ensuring that it is done correctly and on time.

The RR’s core responsibilities include:

• Ensuring the business is registered for the correct taxes (Income Tax, VAT, PAYE, etc.)
• Making sure tax returns are submitted when due
• Ensuring tax payments are made on time
• Acting as the official point of accountability between SARS and the entity
• Ensuring that information provided to SARS is accurate and truthful

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If SARS imposes penalties, interest, or launches an audit, it is the RR they look to first.

Who Must Be Appointed as a Registered Representative?

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The RR must be

• A natural person (not a company)
• Someone with authority and control over the entity
• Someone SARS can reasonably expect to influence compliance

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Typical examples:

• Companies → A director
• Close Corporations → A member
• Trusts → A trustee
• Sole proprietors → The owner
• Non-profits → A responsible office bearer

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In short: the person who ultimately controls the entity should be the RR.

Important: RR vs Tax Practitioner (Accountant)

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This is where many business owners get confused.

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A Registered Representative:

• Is legally responsible
• Carries statutory accountability
• Cannot outsource this responsibility

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A Tax Practitioner (e.g. Thornberry Consulting)

• Is appointed to assist, advise, and act on your behalf
• Handles registrations, submissions, correspondence, and strategy
• Does not replace the RR
• Does not carry legal responsibility

Think of it this way:

The RR holds the steering wheel.

The Tax Practitioner is the professional navigator.

A good Tax Practitioner ensures compliance is done properly — but the RR remains the legally accountable person.

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How Does the Appointment Process Work?

In practice, the process usually looks like this:

1. The entity appoints a Registered Representative (director, trustee, etc.)
2. The RR is linked to the tax profiles on SARS eFiling
3. A Tax Practitioner is then appointed to:
    
   • Act on behalf of the RR
   • Manage submissions
   • Engage with SARS
   • Resolve issues, audits, or disputes

 This structure protects the business while ensuring professional oversight.

Frequently Asked Questions(FAQs)

1.       May a foreigner or South African tax non-resident be a Registered Representative?

Yes, in principle.

SARS allows a foreign national or tax non-resident to be an RR provided they are a director or trustee and can be verified by SARS.

However, in practice, this can be more complex and may require:

·      Additional identity verification

·      Proof of appointment(director/trustee documents)

·      A local Tax Practitioner to assist with administration

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‍2.       What is the difference between a Public Officer and a Registered Representative?

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• A Public Officer is an older concept used mainly for income tax
• A Registered Representative (RR) is the modern, broader role used across all tax types

In many cases, SARS now treats the RR as the primary accountable person.

3.       Can the Registered Representative be changed?

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Yes.

If a director resigns or a trustee changes, the RR can be updated on SARS — but:

• SARS requires formal documentation
• The change must be properly recorded on eFiling
• The new RR must pass SARS verification

This is a process best handled with professional assistance.

4.       I thought this should be my accountant — why isn’t it?

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This is a very common misconception.

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Your accountant or Tax Practitioner

• Cannot legally be the RR unless they are also a director/trustee
• Is there to assist, not to carry statutory responsibility

SARS requires accountability to sit with someone inside the entity, not an external advisor.

5.       What does SARS typically require to appoint a Registered Representative?

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SARS usually requests:

• Certified ID or passport
• Proof of address
• Proof of appointment (e.g. CIPC documents or trust deed)
• SARS verification (Typically a Selfie with ID)
• In some cases, an in-person or virtual verification

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Requirements may differ depending on the entity type.

6.       If I appoint a Tax Practitioner, will I still have access to my tax profiles?

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You have control, but the Tax Practitioner will have the profile on their portfolio. So at any stage the RR can request a tax profile or more specifically a Tax Type (like VAT, Income Tax or PAYE) back to have full access again.

As Individuals you may have shared rights with the Tax practitioner, so that both can view and submit tax returns.

7.       What happens if I don’t appoint a Registered Representative correctly?

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This can lead to:

• Blocked eFiling access
• Delayed tax refunds
• Rejected submissions
• Penalties and compliance flags
• Difficulty resolving SARS queries or audits

SARS is increasingly strict on verification and accountability.

Final Thought

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Appointing a Registered Representative is not just a formality —it is a legal requirement that directly affects your tax compliance and risk exposure.

Working with a professional Tax Practitioner like Thornberry Consulting ensures:

• The correct person is appointed
• The structure is compliant
• Your tax affairs are managed efficiently
• You stay in control while experts handle the complexity

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