It’s one of the most misunderstood topics in church registration: can your church issue Section 18A tax certificates so that donors can claim their donations back from SARS? Many websites imply that simply registering a church means you can. That is not correct. Here are the real rules on Section 18A for a church in South Africa.
Two different SARS approvals — don’t confuse them
There are two separate things people mix up:
- Income tax exemption (PBO status) — approval as a Public Benefit Organisation under Section 30 of the Income Tax Act, so the church itself doesn’t pay income tax. Religious activity is a listed public benefit activity, so a church can qualify for this.
- Section 18A approval — a separate approval that lets your donors deduct their donations from their taxable income. This is much narrower.
The key rule: Section 18A only covers Part II activities
Section 18A receipts may only be issued by an approved PBO for activities listed in Part II of the Ninth Schedule of the Income Tax Act — things like welfare and humanitarian work, healthcare, education and development, and conservation.
Purely religious activities fall under Part I, not Part II. That means a church that only conducts religious activities (services, worship, ministry) can be tax-exempt as a PBO, but cannot issue Section 18A certificates for ordinary tithes and offerings.
When a church CAN issue Section 18A certificates
A church can issue valid Section 18A receipts if it:
- Is an approved PBO with SARS;
- Actually conducts Part II public benefit activities — for example a feeding scheme, a school or crèche, a clinic, or a poverty-relief programme;
- Has applied for and received specific Section 18A approval from SARS; and
- Issues 18A receipts only for donations used for those qualifying activities, keeping the funds and records ring-fenced.
In short: an ordinary offering to fund church services is not 18A-deductible, but a donation to the church’s registered feeding scheme can be. Getting this wrong is a common reason SARS withdraws PBO or 18A status — so it must be set up properly.
Want tax exemption & Section 18A done correctly?
We register your church, apply for PBO status, and set up Section 18A for your qualifying activities — the right way.
Church + Tax Exemption →Frequently Asked Questions
No. Registering a church does not give it Section 18A rights. Section 18A only applies to Part II Ninth Schedule activities (welfare, healthcare, education, etc.). Purely religious activities are Part I and do not qualify, so ordinary tithes and offerings are not 18A-deductible.
PBO status exempts the church from income tax. Section 18A is a separate, narrower approval that lets donors deduct their donations — and only for donations to qualifying Part II public benefit activities.
The church must be an approved PBO, actually conduct Part II activities such as a feeding scheme or school, apply for specific Section 18A approval from SARS, and ring-fence the donations and records for those activities.
Yes. We register churches, apply for PBO tax exemption, and set up Section 18A correctly for qualifying activities so you stay compliant with SARS.
Bekin Consulting handles church registration, tax exemption and Section 18A applications across South Africa.
