With the 2026 Trust Filing Season having opened on 19 September, trustees are operating in an increasingly data-driven compliance environment. This year’s filing season coincides with enhanced third-party reporting requirements and stronger enforcement by the South African Revenue Service (SARS).

A key development is the IT3(t) third-party data return, which requires trusts to report amounts vested in beneficiaries. For the 2026 year of assessment, the filing deadline for these submissions was 30 September 2026. SARS has indicated that information reported through the IT3(t) process may be used to populate beneficiaries’ individual tax returns, making it easier to identify discrepancies between what a trust reports and what a beneficiary declares.

This forms part of a broader third-party data submission period running from 1 September to 31 October 2026, reflecting SARS’s increasing reliance on information received from multiple sources to support compliance and verification.

Trusts are also facing greater consequences for failing to meet their filing obligations. From May 2026, SARS began imposing administrative non-compliance penalties on trusts with outstanding ITR12T income tax returns for tax periods from 2024 onwards. These penalties may recur while the non-compliance remains unresolved.

The practical implication is that trustees should ensure that trust accounting records, ITR12T returns, IT3(t) submissions and beneficiary tax disclosures are all complete, accurate and consistent.

As SARS continues to expand its use of third-party data, discrepancies that may previously have gone unnoticed are becoming easier to identify. For trustees, timely filing and careful reconciliation of beneficiary distributions are therefore becoming increasingly important parts of trust administration. Should you require any professional advice in this regard, do not hesitate to contact our offices.