SARS Proposes to Double The APN Threshold
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Your client needs to send R80,000 to a supplier in China next week. Right now, that means an APN application, eFiling forms, and a waiting game with SARS. A new draft rule from SARS proposes to change that, but not yet.
What just happened
On 8 May 2026, SARS published a Draft amendment to rules under section 120 of the Customs and Excise Act, 1964, proposing lifting the threshold for Advance Payment Notifications (APNs) on foreign exchange payments from R50,000 to R100,000.
In plain terms: if the draft becomes final, importers paying a foreign supplier upfront will only need to lodge an APN with SARS when the payment is more than R100,000. Anything below that, no APN required. The threshold change would apply to import categories 101 (01 to 10) listed in Section J. (H)(i) of the Currency and Exchanges Manual for Authorised Dealers, the standard import payment categories most businesses use.
Important: this is still a draft. SARS has not set an effective date. The current R50,000 threshold remains the law until the final rule is gazetted with a commencement date. Nothing changes in practice yet.
Why this matters for your clients
The APN system was introduced in late 2023 to give SARS better visibility over advance payments to foreign suppliers. An APN is an application submitted by an importer to notify SARS of their intention to make an advance payment exceeding R50,000 to a foreign supplier of goods. This notification process is conducted through SARS eFiling.
It works, but it adds time and admin to every cross-border transaction. As our earlier coverage of the APN process explained, the system has been a mixed blessing for importers, more transparency, but more paperwork.
If the threshold doubles to R100,000, many smaller advance payments will simply fall out of the APN net. Less back and forth with SARS, faster bank payments, less admin for your client.
The currency fluctuation carve-out
The draft also includes a second useful change. Rule 120.13.05A would be amended so that if your client applies for an advance payment of an amount not exceeding R100,000 (so no APN needed), and currency fluctuations later push the rand value above R100,000 before the authorised dealer settles, an APN would still not be required.
Anyone who has watched the rand swing between submission and settlement will recognise the value of this fix.
What to do now
Honest answer: not much, and that's the point.
Don't change anything operationally. The R50,000 threshold is still law. APNs above R50,000 still need to be lodged. Skipping one because "the threshold is going up" will put your client offside.
Keep an eye on the Government Gazette. The change only takes effect once SARS publishes the final rule with a commencement date. That is the moment to update procedures.
Submit comment if it affects you. Draft rules under section 120 typically go out for public comment. If you or your clients have a view, this is the window. Comments on technical SARS rules carry weight, especially from practitioners who deal with the system daily.
Flag it to clients as a heads-up, not a green light. A short note saying "SARS is proposing to double the APN threshold, we'll let you know when it takes effect" positions you as the practitioner who sees these things first, without creating false expectations.
Get your update plan ready. When the final rule lands, you'll want to move quickly: identify affected clients, update internal checklists, brief your team. Doing the prep now means a fast turnaround later.
The bottom line
This is a sensible, practical change that should reduce friction for SME importers, if it gets finalised. For now, it's a draft worth watching, not acting on. The work for practitioners is to stay informed, comment if relevant, and be ready to move when SARS finalises the rule.