14/09/2026
CRS 3.0: THE SELF-CERTIFICATION INDICATOR - What Does “Valid” Really Mean? 💡
In January 2026, SARS released updated Business Requirement Specifications for the annual FATCA and CRS submission covering 1 March 2026 to 28 February 2027, with reporting due by 31 May 2027. The changes are largely driven by the OECD’s Version 3 updates to the XML Schema, requiring SARS to align South Africa’s domestic reporting requirements with the OECD’s CRS framework.
One area requiring particular attention is the self-certification indicator.
Under the updated CRS XML Schema, a Reporting Financial Institution must report whether an account holder has provided a valid self-certification, simply reporting “TRUE” or “FALSE”.
At first glance, this seems straightforward. But the requirement is not merely to confirm that a self-certification was received and completed. The institution must determine whether it is valid.
For an individual, a valid self-certification must include the required information, such as the account holder’s name, residence address, tax residence, TIN and date of birth, and must be dated and signed.
But completeness is only part of the assessment.
The TIN challenge
The OECD CRS Commentaries make it clear that a financial institution may have reason to question a self-certification where a TIN is missing and the relevant jurisdiction is known to issue TINs to all tax residents.
This places an important responsibility on South African Reporting Financial Institutions, while also highlighting the role SARS should play in providing information about which jurisdictions issue TINs and the relevant requirements.
Currently, much of the available information comes from the OECD.
Importantly, a South African Financial Institution is not required to validate the format or technical specifications of a TIN. It may choose to do so, however, as this can improve the quality of information exchanged and support tax compliance.
What does this mean in practice?
When a Reporting Financial Institution reports to SARS that it has received a valid self-certification, it should ensure that:
• All required information has been completed.
• The self-certification passes the required reasonableness assessment.
• Any missing TIN is considered against the information available from SARS and the OECD.
The distinction between a complete self-certification and a valid self-certification is therefore an important one under CRS 3.0 - and one that South African Reporting Financial Institutions should understand before making their next submission.
Contact CRS Mondial for your FATCA & CRS queries.
crsmondial.com • [email protected] • +27 82 411 3262
