Most South African business owners have a mental model of compliance in which SARS is the regulator that bites and the Department of Employment and Labour is the one that sends letters. That model is about eighteen months out of date.
On 8 September the Compensation Fund published a notice in the Government Gazette giving employers until 31 October to submit outstanding Returns of Earnings, with an estimated assessment and a penalty of up to 10% waiting on the other side. The Employment Equity reporting season opened on 1 September and this is the first one that measures movement rather than a starting position. Both of those sit on top of the interim EMP501, which opens on Monday.
Four reports, four regulators' worth of consequences, one payroll file. Here is what falls due over the next six weeks, and why it is really one problem rather than four.
Key takeaways
- The Compensation Fund gazetted a hard deadline of 31 October for outstanding Returns of Earnings for the 2025 assessment year and earlier. Non-submission triggers an estimated assessment and a penalty of up to 10% of the final assessment.
- Employment Equity reporting closes its manual channel on 1 October and its online channel on 15 January 2027. This is year two under the sectoral targets, so the report shows progress against your own plan, not a baseline.
- The interim EMP501 opens Monday 21 September and runs to 31 October, on PAYE BRS version 25.3.0 with a new ITREG source code and mandatory valid employee tax reference numbers.
- 30 September carries the IT3(t) and, for February year-ends, the third provisional top-up.
- SARS's interest rate on outstanding tax rose to 10.50% on 1 September. It pays 6.50% on overpaid provisional tax. That four-point spread is the real cost of a conservative estimate.
- The MPC decides on 23 September with the repo at 7.00%, prime at 10.50% and CPI running at 5.0% against a 3% target. July's hold was a 4–2 vote.
The gazette almost nobody read
On 8 September 2026, in Government Gazette No. 55347, the Compensation Fund gave notice that employers with outstanding Returns of Earnings for the 2025 assessment year and prior must submit them by 31 October 2026 (CRS).
The consequences are specified rather than implied. Where a return is not submitted, the Fund may raise an assessment based on estimated earnings under section 83(6)(a) of COIDA, and impose a penalty of up to 10% of the final assessment under section 83(6)(b) (CRS).
An estimated assessment is worse than it sounds. You do not get to argue about it later from a position of strength, because the estimate exists precisely because you supplied nothing to contradict it. And the downstream effect is the one that hurts a small business: no current assessment means no letter of good standing, and no letter of good standing means you fall out of tender processes and off the approved-supplier lists of every corporate client that checks.
If you are not certain whether your ROEs are current — and a surprising number of owners are not, because the CF-Filing portal has been unreliable for years and people have quietly given up — check now on cfonline.labour.gov.za. Six weeks is enough time. Three weeks is not. Our COIDA reporting is built to produce the return from payroll rather than from a reconstruction.
Employment Equity: this is the year it becomes measurable
The EE reporting season opened on 1 September 2026. Manual submissions close on 1 October 2026; the online window on the EE portal runs to 15 January 2027 (ClearComply).
Designated employers — 50 or more employees, plus every organ of state — submit the EEA2 annual report and the EEA4 income differential statement (ClearComply). The turnover-based test disappeared at the start of 2025, so headcount is now the only trigger. A 55-person business with modest revenue is designated; a 40-person business with large revenue is not.
What changed is what the report is for. The five-year sectoral numerical targets took effect in April 2025 and run to 2030. Last season's submission established a baseline and a plan. This season's is the first substantive assessment of employers' annual goals against those benchmarks (Webber Wentzel, ThriveCFO). The disability target moved from 2% to 3% across all sectors (ClearComply).
The enforcement side is not theoretical. A first contravention carries the greater of R1.5 million or 2% of annual turnover, rising to the greater of R2.7 million or 10% of turnover for repeat contraventions (Webber Wentzel). Separately, under section 53, an EE Compliance Certificate is a prerequisite for doing business with the state (ThriveCFO).
Here is the part that gets missed in most SME conversations about this. The EEA4 is a payroll document. It reports remuneration by occupational level and demographic group, and it is the mechanism through which equal pay for work of equal value becomes visible to an inspector. It is built from the same earnings data that produces your EMP501, and if the two disagree, the disagreement is now in writing, filed with two different departments, under your signature. Our Employment Equity reporting draws both from the same ledger for exactly that reason.
Against a national minimum wage of R30.23 per hour since 1 March 2026 and a BCEA earnings threshold of R269,600.90 a year since 1 May 2026 (DLA Piper), the bottom of your pay scale is where both of those documents are most likely to be wrong at once. Our BCEA guide covers what the threshold changes.
The EMP501 opens Monday, and the blocker has not changed
The interim employer reconciliation runs 21 September to 31 October 2026, covering 1 March to 31 August (CRS).
It runs on PAYE BRS version 25.3.0, published in May 2026, which introduces a new ITREG source code for individual income tax registration along with minor changes to source code validations and descriptions (CRS). A new e@syFile Employer build was due mid-September, and the thin client remains the only submission channel (SARS).
The thing that stops submissions is the same thing that stopped them last year: an employee without a valid income tax reference number. Valid employee tax numbers are mandatory, and one missing number does not produce a warning on one certificate — it blocks the file. We went through this cycle in full in September's employer windows.
If you do nothing else this week, run the list. Every person who was on your payroll at any point between 1 March and 31 August, with their tax number, and a flag on every blank. That takes an hour now and a fortnight in the last week of October, when SARS's channels are congested and the employee in question left in May and is not answering their phone.
30 September, and the cost of being wrong in either direction
Two things land on the 30th. The IT3(t) third-party return for trusts, which prepopulates the ITR12T that opened for filing on 19 September — covered in this season's prepopulated returns. And, for businesses with a February year-end, the third [provisional tax](/blog/provisional-tax-irp6-south-africa) top-up payment.
The top-up is where the interest rate matters. On 1 September 2026 SARS's rate on outstanding taxes rose to 10.50%, and the rate it pays on overpaid provisional tax rose in step to 6.50% (SARS Table 1, SARS Table 2). They were 10.25% and 6.25% until 31 August.
That spread is the whole argument for getting the estimate right rather than safe. Underpay, and you are borrowing from SARS at 10.5%. Overpay, and you are lending to SARS at 6.5% — in a year when your bank is charging you prime at 10.50% for the overdraft you needed because the money is sitting at SARS. Neither error is free, and the expensive one is the one most SMEs choose deliberately, because a conservative estimate feels prudent.
The estimate is only as good as your management accounts for the six months to 31 August. Which is the same six months as the EMP501. Which is the same payroll data as the EEA4.
What the MPC does on Wednesday
The Monetary Policy Committee announces on 23 September. The repo rate is at 7.00%, prime at 10.50%, and June CPI came in at 5.0% against the Bank's 3% target with a one-point tolerance band. July's decision to hold was a 4–2 vote, with two members pushing for a further 25 basis points (The Global Banker, SACalc).
One member changing their mind carries a hike. That would take prime to 10.75% and, with the usual lag, SARS's rate on outstanding tax with it.
This is not a compliance item. It is the reason the compliance items are worth taking seriously this particular October. A 10% COIDA penalty, a 10% EMP501 late-submission penalty and an underestimation penalty are all survivable individually in a good year. In a year where GDP contracted 0.2% in the second quarter (BusinessTech) and the cost of the overdraft is going up rather than down, they compound into something that shows up in your December cash flow.
One dataset, four reports
Step back from the individual deadlines and the pattern is obvious.
The EMP501 says what you paid your staff and what you withheld. The Return of Earnings says what you paid your staff, for a different purpose, to a different fund, on a different definition of earnings. The EEA2 and EEA4 say who your staff are and what each group is paid. The provisional estimate says what the business earned while paying them.
Four reports. One underlying set of facts. Four different departments with the statutory power to ask.
For most South African SMEs those four reports are produced in four different places by three different people, at four different times, from four different extracts of the same payroll. The reports do not agree, not because anybody is dishonest, but because a spreadsheet exported in April and a spreadsheet exported in September were taken from different versions of the truth.
That used to be survivable, because nobody compared them. It is becoming less survivable, because the comparison is getting cheaper for the regulator every year. SARS already prepopulates from third-party data. The EE portal already holds your sector's targets and your own stated plan. The Compensation Fund can now raise an assessment on an estimate and make you disprove it.
The work is no longer producing the reports. The work is being able to show that they all came from the same place.
Why we build it this way
Bluubin has run South African accounting and statutory payroll on a single live ledger for nineteen years, and this fortnight is the argument for that design.
- One ledger, so the earnings figure behind the EMP501, the Return of Earnings and the EEA4 is one number with one history rather than three extracts that agree by luck.
- PAYE, UIF and SDL calculated against tax tables maintained as versioned code.
- EMP201, EMP501 and IRP5 with e@syFile export through tax-year-versioned exporters, so a historical period still submits against the specification that applied at the time.
- Pre-submission validation that blocks the export until the data is complete and links each error to the screen that fixes it — including the missing tax reference number that would otherwise stop you in the last week of October.
- ETI calculated automatically each payrun.
- Employment Equity and COIDA reporting built in, which most SME accounting and payroll products in this market simply do not address at all.
Software does not make you compliant and the responsibility stays with you. What it changes is how long it takes to answer a question you will be asked four times this season in four slightly different forms: what did you pay your people between March and August, and can you prove it consistently.
There is a thirty-day trial with full access and no credit card if you want to run it against your own numbers.
If you take two things from this article: check today whether your Returns of Earnings are outstanding, and pull the list of employees without valid tax reference numbers before Monday. Those two checks remove most of what can go wrong between now and 31 October.
This guide is general information to help you get oriented — it isn't formal tax or legal advice. Thresholds, rates and deadlines change, so confirm the current figures on the SARS website or with your accountant before you act.