"Only accountants can save the world — through peace, goodwill, and reconciliations." (Unknown)

Employers are legally required to submit their EMP501 reconciliation with accurate and up-to-date payroll and tax information (including valid Income Tax Reference Numbers) for their employees during the Employer Annual Declaration season that runs from 1 April to end May 2026.

This involves submitting an accurate Employer Reconciliation Declaration (EMP501), issuing Employee Tax Certificates [IRP5/IT3(a)s] and, if applicable, a Tax Certificate Cancellation Declaration (EMP601).

The submission must further balance across the three elements: monthly EMP201 returns for the period, the payments made to SARS, and the employees’ IRP5/IT3(a)s generated. As such, it provides an important opportunity to correct any errors that may have occurred during the year.

Preparing and submitting a correct and complete declaration on time can be technically challenging, especially for larger employers. But you neglect it at your peril, as it is a focus area for SARS and the consequences of non-compliance are many.

SARS focus area

The Annual Employer Reconciliation Declarations is a focus area for SARS, as it not only ensures employer compliance, but also enables SARS to issue individual taxpayers with pre-populated Income Tax Returns (ITR12) and income tax auto-assessments.

For this reason, employers can expect ongoing and increased scrutiny from SARS in this regard.

Technical challenges

Submitting a declaration that is correct, complete and on time (before end May) has always been technically challenging. But it just got even harder, as SARS has now upgraded missing or incorrect mandatory Income Tax Reference Numbers from a warning-level defect into a hard-stop submission defect when completing a declaration.

This means that employee details must be verified before submission and employees without tax numbers must be registered with SARS before the company EMP501 can be submitted. Missing or invalid employee tax numbers result in incomplete submissions that will prevent IRP5 certificates from being captured, causing delays and non‑compliance for the company and all employees.

Because so many employers struggle with technical challenges like these, SARS is rolling out technical clinics this year to make compliance easier. Or you could just let us handle it for you.

Consequences of non-compliance

Submitting incorrect or incomplete details, or submitting after the deadline, can result in:

· Additional admin, time and cost

· Employer penalties

· Delays in obtaining an employer’s tax compliance status

· Unexpected tax outcomes for employees

In addition, if the EMP501 submitted is audited by SARS and PAYE liability is amended, the employer is required to re-submit the EMP501 as per the audit result.

Expert assistance is at hand

As the deadline looms, employers can be assured of technical challenges, increased SARS scrutiny, and even more tax-related admin and cost. All very good reasons to rely on our tax expertise and experience to ensure you submit correctly and on time.