Under the draft Crypto Asset Manual, South Africa exchange control would treat a withdrawal from Luno or VALR to Binance or to your own cold wallet as an export of capital. It would count against your R2 million single discretionary allowance. Werksmans and Luno read the draft as banning transfers from a self-custody wallet back into a local exchange.
Comments on the manual closed on 30 September 2026. On 21 October 2026, in the MTBPS, Minister Godongwana said a different approach is needed and promised a revised second draft, without giving a date. That leaves you filing by the 23 October 2026 non-provisional deadline and planning transfers with three things in play: the current law, a first draft and a promised second draft.
I'm Chris Herbst, Managing Director at CH Consulting. I am a Chartered Business Accountant in Practice, CBAP (CIBA), with the Chartered Institute for Business Accountants, and a General Tax Practitioner, GTP (SAIT), with the South African Institute of Taxation. Our practice prepares crypto schedules and ITR12 disclosures for individuals who trade on Luno, VALR and offshore platforms, including rebuilding base cost for crypto that has moved between exchanges and cold wallets.
What does the Crypto Asset Manual change for South Africa exchange control on crypto?
The draft Crypto Asset Manual makes a crypto transaction cross-border, and reportable to the SARB's Financial Surveillance Department (FinSurv), when crypto moves from a domestic Authorised crypto asset service provider (CASP) to an offshore CASP, or to a non-custodial wallet where you hold the private keys.
This trigger point is set out in the SARB's statement of 3 August 2026 on the draft manual. The crypto does not have to cross a border, and its ownership does not have to change. A withdrawal from VALR to your own hardware wallet is caught in the same way as a withdrawal to Binance. Baker McKenzie notes that a transfer to a client's own self-hosted wallet "would be classified as an export of capital".
Would Luno or VALR report my withdrawal under the draft?
Yes. Under the draft, the local exchange identifies the cross-border transfer and reports it to FinSurv. Daily Maverick reports that the transaction threshold value is "left entirely blank in the draft text". So the draft does not yet say whether small withdrawals are handled differently.
Who is allowed to move crypto out under the draft?
Only individuals. SANews reports the position as "Only individuals, at this stage, will be allowed to externalise crypto assets via Authorised CASPs". They must do so within their single discretionary allowance or foreign capital allowance. Dear South Africa reads the draft as barring resident companies and trusts from crypto transactions that count as an import or export of capital.
Is the Crypto Asset Manual law yet, and what did Godongwana say in the MTBPS?
The Crypto Asset Manual is not law. It is a draft, and the SARB says it does not yet reflect comments on the draft Capital Flow Management Regulations, so both documents can still change.
The draft Regulations were published on 17 April 2026. The manual followed on 3 August 2026, and comments closed at close of business on 30 September 2026. Luno then objected publicly. Bizcommunity reported on 7 October 2026 Luno's warning that crypto "can leave a South African platform but can never return, even from a customer's own private wallet".
What did the Minister say on 21 October 2026?
TechCentral reports that Minister Godongwana said: "It is clear that we need to take a different approach to these amendments." He added: "We must aim to shift away from pre-approvals. Instead, we must assess transactions for legitimacy and tax compliance." ITWeb quotes his undertaking that "Consultations will commence, with the aim of publishing a revised second draft of the regulations for further input."
When will the revised second draft be published?
The Minister gave no date and did not say which provisions would change. Treasury received thousands of comments. Don't restructure your holdings because of the first draft. Instead, build the records now that a "legitimacy and tax compliance" test will ask for, because that test points straight at SARS data.
Which South Africa exchange control rules apply today, while the Crypto Asset Manual is a draft?
The Exchange Control Regulations, 1961 apply today. In Mangundhla v SARB, the High Court held that Bitcoin is capital, and that it is exported once it is credited to a wallet on a foreign exchange, even if you can reach that wallet from inside South Africa.
What did the Mangundhla judgment decide?
According to Werksmans, Wilson J held that Bitcoin is "plainly capital" under regulation 10(1)(c). He called the earlier Standard Bank decision "clearly wrong". ENS summarises the facts. Between 2018 and 2020, just under 1,680 Bitcoin, worth just under R182 million, was moved to wallets that could be reached only through exchanges registered outside South Africa. About R6 million was declared forfeit under regulation 22B.
What happened to Standard Bank v SARB?
In Standard Bank v SARB, 2025 (5) SA 289 (GP), Motha J held that crypto is neither "currency" nor "capital" under regulations 3(1)(c) and 10(1)(c). The SARB has appealed, and the judgment is suspended until the appeal is decided, so its findings are not in effect.
Does a transfer to my own cold wallet use my allowance today?
Neither SARS nor the SARB has published a position on whether a transfer to a self-custody wallet uses the SDA under the 1961 Regulations. Mangundhla dealt with wallets on foreign exchanges. Keep your total transfers to offshore exchanges within the R2 million SDA in each calendar year, and get SARS approval before you move larger amounts.
How does moving crypto to Binance or a cold wallet affect my offshore allowance?
Under the draft manual, every withdrawal from Luno or VALR to Binance or a cold wallet would count against the same calendar-year single discretionary allowance you already use at the bank for travel, gifts and offshore investment.
The shared limit is the part people tend to miss. A holiday paid through your bank and a Ledger withdrawal in the same calendar year would both come out of one R2 million allowance.
Is the single discretionary allowance R1 million or R2 million?
It is R2 million per calendar year. Exchange Control Circular No. 6/2026 raised it from R1 million. SARS's Budget 2026 FAQ confirms that resident individuals can transfer up to R2 million a year without a TCS PIN for Approval of International Transfers.
What do I need to move more than R2 million?
Above R2 million you need the foreign capital allowance of up to R10 million, which SARS calls the investment allowance. It requires a TCS PIN for Approval of International Transfers (AIT). SARS's AIT supporting-documents page asks for a statement of assets and liabilities for the previous three tax years. Where crypto is the source of funds, it also asks for a "Trading account statement reflecting the trade of the crypto asset" and a bank statement. You must select "Crypto Assets" under "International Investment Type Details". SARS declines applications that use the wrong investment type.
What is the Category One remittance limit in the draft?
The draft also sets up a separate Category One remittance service. Werksmans reports that it is capped at R5,000 per transaction per day and R25,000 per month. It suits small payments, not moving an investment portfolio.
Can I send crypto from my cold wallet back to Luno or VALR under the draft manual?
Not under the first draft as Werksmans, Ledger Insights and Luno read it. A transfer from a non-custodial wallet into a South African exchange would be non-permissible, and crypto could come in only directly from an offshore Authorised CASP.
Ledger Insights describes the draft as one that "bans all inbound transfers from self-hosted wallets". Sending crypto out to a self-hosted wallet would still be allowed, but it would be treated as an offshore transfer even if you plan to use the crypto in South Africa.
What does the one-way rule mean for crypto already in my cold wallet?
If the ban survives into the revised draft, crypto in a cold wallet could not go back to Luno or VALR to be sold for Rand. You would have to sell it offshore or send it through an offshore Authorised CASP. A sale offshore is still taxable for a South African resident. The Comprehensive Guide to the ITR12 asks separate questions about disposals of local and foreign capital assets, and crypto is included in both.
Should I move my crypto back to Luno before the rules start?
Decide based on your own investment needs, not on a first draft that the Minister has already said needs a different approach. If you do move crypto back, record the transfer like any other, because it will show up in your exchange's CARF data. In May 2026 the authorities said the draft Regulations do not criminalise possession and are not retrospective.
Is moving crypto to my own cold wallet or Binance account a taxable event for SARS?
SARS's draft Guide to the Taxation of Crypto Assets says the tax result of a transfer between your own wallets depends on the "specific facts of the transfer". We treat a transfer between wallets you own as a non-disposal and flag each one, so that SARS does not read it as a sale.
Three facts decide it: whether you own both the sending and receiving wallet, whether you control the keys or the account at the destination, and whether you received anything in return. The draft guide was published on 1 July 2026 and comments closed on 31 August 2026. It is not a binding general ruling under section 89 of the Tax Administration Act. Crypto is not currency for tax purposes, so section 24I does not apply. Whether a gain is revenue or capital depends on your facts. Exchange control and tax are separate systems: a transfer that the SARB treats as an export of capital is not a disposal for SARS for that reason alone.
Are network and withdrawal fees paid in crypto a disposal?
SARS has not published guidance on whether crypto units spent on network or withdrawal fees are a disposal. Record the fee units as a disposal at market value. Add the fee to the base cost of the transferred units only where you can support it.
How do I carry base cost from Luno to Binance?
Rebuild base cost from your Luno or VALR purchase history and carry it with the units through each transfer, because Binance and your hardware wallet have no record of what you paid. For identical units held on capital account, the draft guide lists specific identification or first-in-first-out (FIFO). SARS has not published whether the FIFO queue runs per wallet, per platform or across all your holdings. Use one method across every platform and write it down in a schedule. Our guide to calculating crypto capital gains tax walks through the arithmetic.
Where does crypto go on the ITR12?
SARS's Budget 2026 FAQ says crypto trading is declared on the ITR12 and that gains and losses on all transactions must be reported. It gives source code 4522 for crypto trading income and an 18% maximum effective CGT rate for individuals. Check the code against the form before you file. Disposals on capital account on an offshore platform go under the foreign capital asset questions. Our step-by-step ITR12 crypto guide shows each screen.
How do Luno, VALR, Binance and cold-wallet transfers compare under the draft manual?
Under the draft manual, transfers out of Luno or VALR to Binance or a cold wallet are allowed but count as exports of capital, while transfers from a cold wallet back into a local exchange are non-permissible. For tax, only a sale is a clear disposal.
- Luno or VALR to Binance: Under the draft manual: Export of capital; Tax position: Facts decide
- Luno or VALR to your Ledger: Under the draft manual: Export of capital; Tax position: Facts decide
- Cold wallet to Luno or VALR: Under the draft manual: Non-permissible; Tax position: Facts decide
- Offshore Authorised CASP to Luno or VALR: Under the draft manual: Permitted inbound; Tax position: Facts decide
- Sale on any platform: Under the draft manual: Not a transfer; Tax position: Taxable disposal
- Network fee paid in crypto: Under the draft manual: Part of the withdrawal; Tax position: No SARS guidance
- Company or trust to Binance: Under the draft manual: Not permitted; Tax position: Entity rules apply
"Facts decide" means the transfer is a non-disposal where you own and control both wallets and receive nothing in return. If a third party controls the destination, the facts point to a disposal or a donation.
What does SARS already hold about my crypto transfers, and how does a mismatch show up?
SARS already receives information directly from local exchanges. From 1 March 2026, reporting CASPs also collect CARF data on your identity, tax number and number of wallets, together with aggregated purchases, sales and "crypto-asset wallet transfers".
What does CARF report about my transfers to a hardware wallet?
SARS's CARF page says the first reporting period runs from 1 March 2026 to 28 February 2027. The return is due on 31 May 2027, and the first international exchange takes place in September 2027. Individuals do not report under CARF. The OECD model reports the number of units and the total value sent to wallets not linked to a service provider, but not the wallet address. Your base cost is not reported either. Local exchanges are asking existing customers to confirm their tax residence, as we explain in our CARF self-certification article.
What does my AIT application tell SARS?
Each AIT application includes statements of assets and liabilities, with crypto shown at cost. SARS renamed the "Net Worth" field under "Assets and Liabilities Details" to "Net Amount (At cost)". These figures can be compared with your earlier and later ITR12 disclosures.
How does a mismatch reach me?
Expect a letter that compares your CARF disposal and transfer totals with the capital gains and source codes on your ITR12. In its 9 October 2024 release, SARS said it "has recently issued query letters" and exchanges information with other tax authorities. A query can lead to an audit and a request for relevant material. Our article on the section 46 letter explains who can respond for you.
What should I do now about my Luno, VALR, Binance and cold-wallet records?
Start by filing correctly by your deadline, then build a transfer register and a base cost schedule that SARS can match to its CARF data.
- File your ITR12 on time. Non-provisional taxpayers file by 23 October 2026, and provisional taxpayers by 22 January 2027 (see our 2026 deadlines guide).
- Export full histories. Download the complete transaction history for every Luno wallet, your VALR account and Binance, along with bank statements showing Rand going in and out. Our Luno reconciliation guide and VALR guide cover each export.
- Build a transfer register. For each withdrawal, record the date, the units, the txid, the destination address, the travel-rule declaration, and proof that you control the destination, such as a signed message or a hardware-wallet export. Luno says it asks for the recipient's name and the recipient's CASP under FIC Directive 9, which CASPs had to apply by 30 April 2025. Section 8 of the Directive deals with unhosted wallet transfers.
- Fix your base cost method. Choose specific identification or FIFO, carry the cost of each unit through every transfer, and document the method.
- Reconcile to the CARF categories. Match your purchases, disposals and transfers out against your ITR12, and keep the reconciliation on file.
- Track your SDA by calendar year. Add up bank transfers, travel and crypto sent to offshore exchanges against the R2 million limit.
- Apply for an AIT before larger transfers. On eFiling, request a TCS PIN for Approval of International Transfers. Select "Crypto Assets" under "International Investment Type Details" and complete "Assets and Liabilities Details" at cost.
- Keep a dated wallet inventory. The draft Regulations would require crypto to be declared within 30 days of obtaining control, with fines of up to R1,000,000, imprisonment of up to five years, or both. An inventory lets you declare quickly if that rule is finalised.
- Keep records for five years. Section 29(3) of the Tax Administration Act allows records to be discarded only five years after the return is submitted.
What are the most common mistakes when moving crypto off Luno or VALR?
The most common mistake is treating a withdrawal as a private wallet matter when, under the draft manual, it uses your offshore allowance, and in SARS's data it looks like an outflow that needs explaining.
Counting the SDA only at the bank
People track what their bank sends offshore and forget their crypto withdrawals. Under the draft, both come out of the same R2 million calendar-year allowance.
Letting base cost disappear at the transfer
Binance has no record of your Luno purchase price. If you don't carry the cost across yourself, a later sale on Binance looks like a gain on the full proceeds.
Getting the travel-rule declaration wrong
Declaring a third party's wallet as your own, or your own wallet as a third party's, creates records that will not reconcile later. Binance's South African transfer-information requirements took effect on 30 April 2025.
Leaving crypto off the ITR12 because no Rand came back
Swapping one crypto for another, or selling on Binance, is declared whether or not money reaches your bank. Platforms generally do not issue an IT3(b) or IT3(c), so you have to build the figures yourself from your transaction histories.
Filing an AIT that does not match your returns
Your AIT statement of assets and liabilities shows your crypto at cost. If those holdings are missing from earlier returns, the application itself brings the gap to SARS's attention.
Waiting for a SARS letter before correcting
Under the section 223 table, understatement penalties in a standard case run from 10% to 150%. A voluntary disclosure made before you are notified of an audit brings them down to between 0% and 10%. Once SARS has identified you for audit, the VDP is closed. Read our VDP guide for undeclared crypto before a CARF query arrives.
Do You Need Help With the Crypto Asset Manual and Your Wallet Records?
If you have moved crypto between Luno, VALR, Binance and a cold wallet, we can rebuild your base cost, reconcile your transfers to the CARF categories, check your allowance usage and prepare your ITR12 or AIT application. Book a call to talk through your own circumstances, or email info@chconsulting.co.za with your questions.
