Luno SARS reporting 2026 does not mean SARS is holding a line-by-line copy of your trades. Under the Crypto Asset Reporting Framework, a South African crypto asset service provider reports annual per-asset aggregates: gross amounts paid and received, total units and a transaction count. The first of those reports is only due at SARS by 31 May 2027.
South Africa implemented CARF on 1 March 2026, after SARS published the Final External BRS V 1.5 on 16 February 2026, and its Filing Season 2026 media release lists “More accurate Auto Assessments driven by expanded third-party data sources” among this year’s enhancements. That creates an awkward gap: the 2026 ITR12 you are filing between 13 July and 23 October 2026 covers a year that ended before CARF started, while the year SARS will eventually be able to check is the one running right now.
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 rebuilds Luno, VALR and AltCoinTrader trade histories into disposal schedules for South African individual taxpayers, and defends those schedules when SARS asks for supporting documents.
What does Luno SARS reporting 2026 actually consist of?
Under CARF, a reporting crypto asset service provider sends SARS the aggregate gross amount paid and received, the aggregate number of units and the number of transactions, separately for acquisitions and disposals, per crypto asset, in the fiat currency in which the amounts were paid or received, as set out in practitioner guidance on the CARF standard. SARS itself confirms that CARF “requires Crypto Asset Service Providers to report certain crypto asset transaction information to SARS” and that individual taxpayers do not report directly under CARF; the obligation sits with the service provider. Luno (Pty) Ltd is a licensed South African provider, appearing on the FSCA’s published list of authorised CASPs with FSP number 53314.
Is the CARF record transaction-level?
No. What arrives is an annual summary per asset plus a count of how many transactions produced it, not a trade ledger. That distinction matters, because a count of 412 disposals of BTC in a year is not proof of what you earned, but it is powerful evidence about how you were behaving.
Are the amounts in Rand or in the currency of the trade?
The OECD schema that SARS implements requires each amount to carry a three-character ISO 4217 currency code, and amounts are reported in the fiat currency in which they were paid or received. Whether SARS’s own BRS V1.5 obliges local providers to convert everything to Rand is not something we have been able to verify, and we have not seen SARS publish a position on it. Treat any statement that CARF delivers Rand values to SARS as unconfirmed until you have read V1.5 yourself.
How precisely are amounts and units reported?
The CARF XML Schema records the Amount element net of transaction fees, entered with two-digit fractional amounts of the currency in question, and the Number of Units element up to the sixth decimal place. Net of fees is the detail most taxpayers miss, and we return to it below.
Do staking and wrapping get their own classification?
CARF carries an optional ExchangeType element with codes including CARF401 Staking, CARF402 Crypto Loan, CARF403 Wrapping and CARF404 Collateral. A wrap or a collateral posting that you treat as a non-event still lands at SARS as a tagged relevant transaction, which is a difficult conversation to have two years later with no records.
When does SARS actually receive the first Luno CARF report?
The first CARF reporting period runs 1 March 2026 to 28 February 2027, the return for that period must reach SARS by 31 May 2027, and the initial exchange of CARF information between participating jurisdictions takes place in September 2027. Nothing from CARF covers the 2026 year of assessment, which ran 1 March 2025 to 28 February 2026.
- 2026 ITR12 (1 Mar 2025 to 28 Feb 2026): CARF position: No CARF data exists; Status: Outside CARF
- 2027 year (1 Mar 2026 to 28 Feb 2027): CARF position: Aggregates due at SARS 31 May 2027; Status: Reconciliation exposure
- Exchange with foreign authorities: CARF position: First exchange September 2027; Status: Date published
- Pre-population of the ITR12: CARF position: Not stated by SARS; Status: No SARS guidance
Will my Luno trades show up on my 2026 auto-assessment?
They cannot come from CARF, because the first CARF submission is only due in May 2027. SARS expected to issue approximately six million auto-assessments in the 1 to 12 July 2026 window, and by the end of 1 July 2026 more than 1.9 million taxpayers had been auto-assessed with about R8 billion in refunds paid within 72 hours, per its Filing Season 2026 release. If your auto-assessment is silent on crypto and you had disposals, accepting it does not make the omission go away. Our note on relying solely on auto-assessments sets out why, and how to dispute a 2026 auto-assessment covers the mechanics.
Will CARF pre-populate the 2027 return?
SARS says auto-assessments are driven by expanded third-party data, but has not said crypto is one of those sources. Some practitioners expect a pre-populated crypto container from 2027; others expect CARF to be used for risk selection and verification only, with the return left blank. Because the CARF return is due 31 May 2027 and the 2027 filing season is likely to open around the same time, SARS has not said whether the data will reach returns in the first year. Declare your crypto yourself on the 2027 return rather than waiting for a pre-populated figure.
Why does Luno not send you a tax certificate?
Luno does not issue tax certificates, and Marius Reitz of Luno has explained that calculating tax on Bitcoin earnings requires consideration of multiple factors, so transaction histories are not “SARS-ready” documents. What Luno does provide is a downloadable wallet statement for each wallet, recording trades for the period you select, which you then use to calculate your own position.
Does Luno issue an IT3(b) or an IT3(c)?
We have seen no indication that it does, and crypto platforms in South Africa generally do not. SARS does publish a clarification document for IT3(c) reporting of base cost for crypto assets, which tells you the form contemplates crypto, but not that any particular platform files one. We covered the same point for another exchange in why IT3(b) and IT3(c) forms are not supplied by platforms like AltCoinTrader.
How does a Luno CSV export differ from the CARF record?
The CARF record is one classified event per exchange with an aggregate amount net of fees, while a Luno export splits the same trade into separate unlinked rows across two different wallet files with fees buried inside the amounts. The mismatch is one of shape rather than substance, and reshaping the export is the actual work.
The export is per wallet, not per account
You open each wallet, scroll to Download Statement, create the statement and repeat for every wallet you used: ZAR, BTC, ETH, USDC, savings wallets and anything else. Luno delivers a zip file by default that has to be unzipped. Miss one wallet and an entire asset’s disposals disappear from your calculation, while the CARF report will still show that asset.
A trade does not look like a trade
Luno records the components of a trade as deposits and withdrawals: the fiat leg as a withdrawal, the fee as a withdrawal, the asset bought as a deposit. A single Bitcoin purchase therefore appears in the ZAR wallet file and the BTC wallet file as separate rows with nothing linking them. To produce a disposal schedule you have to re-pair the legs by timestamp.
Fees are inside the amounts
Import guidance notes that although fees are not separated in the Luno export, they are included in the amounts. Because CARF amounts are reported net of transaction fees, a taxpayer who uses a fee-inclusive figure and then also deducts the fee as base cost has double-counted, and has done so against a SARS figure that was already net.
The API alternative
Luno supports read-only API keys created under Profile, then Security, then API keys, with phone authorisation, per third-party integration documentation. That reduces the chance of missing a wallet, but it does not solve the pairing or the fee problem.
How do you reconcile Luno before you submit the ITR12?
Reconciling means building a per-asset annual summary in the same shape CARF uses, then tying your declared figures to it. Work through the following in order.
- Export every wallet statement from Luno: Wallets, select the wallet, Download Statement, set the begin and end dates for the year of assessment, choose CSV, Create Statement, Download, then unzip.
- Write down the full list of wallets on your account and tick each one off as you export it, savings wallets included.
- Re-pair the legs by timestamp into single trade events showing date, asset out, units out, asset in, units in and fee.
- Summarise per asset: gross amount paid and units acquired with a transaction count, and gross amount received and units disposed with a transaction count. That is the CARF shape.
- Record your currency conversion policy for any leg that was not in Rand, and keep the rate source with the file.
- Choose and document your base cost method, then apply it consistently across the whole year.
- Flag every transfer out to a private wallet with the destination address and the later disposal it relates to, so the outflow is not mistaken for a sale.
- Separate staking and savings rewards from trading results; they are receipts or accruals in their own right, not disposals.
- Decide revenue or capital, then complete the correct container on the ITR12 and check the source code on SARS’s current Find a Source Code tool before you use it.
- Save the export files, the paired schedule, the per-asset summary and your method notes as one pack. Our list of documents needed to file in 2026 covers what else belongs alongside it.
If you trade with any frequency, check your provisional position at the same time. SARS’s own crypto FAQ puts receipts and accruals from trading in crypto assets into the amount declared on the IRP6, which means a Luno trader who only thinks about tax in October has already missed two payment dates. See how to calculate the first IRP6 for 2026.
Is your Luno profit capital or trading income, and which source code applies?
SARS’s position is that crypto income can be taxed on revenue account under “gross income”, or the gain may be capital in nature under the Eighth Schedule, with the determination tested under existing jurisprudence. SARS has not issued an Interpretation Note or a Binding General Ruling on crypto assets, so the classification rests on your documented facts.
The two competing positions
On one view, high frequency and short holding periods evidence a scheme of profit-making, making the result revenue in nature, taxable at your marginal rate, with losses deductible subject to ring-fencing. On the other, a long-term holding intention survives incidental trading, making the result capital, with a 40% inclusion rate and a maximum effective rate of 18% for individuals. CARF hands SARS a transaction count per asset per year, which is precisely the fact pattern evidence for the first view.
Which codes are involved
Codes recorded for crypto in a 2021 filing season document are 2572 for crypto assets profit, 2573 for crypto assets loss, 6520 and 6521 for gain and loss on local crypto financial instruments, and 6546 and 6547 for the foreign equivalents. Because that source is several years old, confirm each code on SARS’s current Find a Source Code tool before capturing it.
Can you claim a Luno loss against your salary?
Crypto asset activities were added to the “suspect trades” list in section 20A of the Income Tax Act, under which an individual’s losses may be ring-fenced in certain circumstances. Whether SARS is applying section 20A systematically to crypto losses is not something we can verify. Our article on crypto losses on your tax return deals with the practical choice.
FIFO or weighted average: which base cost method should you use?
There is no settled answer, and this is where a Luno reconciliation most often diverges from what SARS holds. SARS’s IT3(c) clarification adds wording to Field 100, Base Cost, stating that for the reporting of base cost for crypto assets it constitutes “identical assets”, which points toward weighted-average treatment. Most consumer crypto tax tools default to FIFO for South Africa.
What that means in a volatile year
The two methods produce materially different gains where you bought the same asset repeatedly at different prices, which is the normal Luno pattern. Pick one, apply it across every asset and every year consistently, and keep a written note of the choice so that a later query is answered from the file rather than from memory. Our guide to calculating crypto capital gains tax works through the arithmetic.
Which annual exclusion applies
For the 2026 ITR12, covering the year ended 28 February 2026, the annual capital gains exclusion is R40 000. The increase to R50 000 takes effect from 1 March 2026, so it first applies to the 2027 year of assessment, the same year CARF covers.
What does SARS already hold, and how would a mismatch show up?
For the 2026 return SARS holds no CARF data, but it does hold third-party data submitted under section 26 of the Tax Administration Act, including IT3(b), IT3(c), IT3(d), IT3(f) and IT3(t) returns, which it uses to pre-populate returns, verify accuracy and identify discrepancies. Crypto is generally absent from that set, so the visible trace is usually banking.
Bank inflows from Luno
Rand withdrawals from Luno into a South African bank account are visible through banking data and through your own statements on verification. A taxpayer with regular Luno inflows and no crypto disclosure is an obvious selection candidate, which is one of the patterns in our piece on red flags that trigger SARS audits.
Section 46 requests still exist
In 2021, AltCoinTrader, Luno and VALR confirmed SARS had approached them for information on a selection of customers in terms of section 46 of the Tax Administration Act, as part of a tax risk assessment on residents involved in mining, speculation or investment in crypto assets. Luno’s Marius Reitz said at the time that Luno “does not share customer information with Sars on a routine or ongoing basis“. That targeted power operates independently of the annual CARF cycle.
What a mismatch letter will ask for
Because CARF delivers proceeds-side aggregates and no base cost, SARS can see what was sold and for how much, but not what you paid. The predictable result from 2027 onward is a verification letter comparing declared proceeds to CARF aggregates, with the onus on you to prove base cost. Our guide to SARS verification of supporting documents explains what a usable response looks like.
What are the most common mistakes we see on Luno filings?
The recurring errors are structural rather than arithmetic, and they survive from one year to the next because nobody revisits the method.
Reconciling only Rand in and Rand out
Because CARF captures crypto-to-crypto exchanges and staking, a reconciliation built from your FNB or Capitec statements alone produces a figure that cannot match the CARF aggregate on any view.
Treating a swap as a non-event
Many users still believe tax arises only on withdrawal to a bank account. SARS’s stated position is that normal income tax rules apply and gains or losses must be declared, and CARF reports both legs of a crypto-to-crypto exchange with unit counts on each side. SARS’s Draft Guide to the Taxation of Crypto Assets, published on 1 July 2026 with comment due 31 August 2026, addresses swaps, but it states that it is not an official publication as defined in the Tax Administration Act and is not a binding general ruling. The strongest available SARS statement on swaps is therefore non-binding and still out for comment.
Leaving self-custody transfers undocumented
A transfer from Luno to your own hardware wallet is a reportable transfer at SARS but is not a disposal for tax. Without a documented destination address and a matching later disposal record, the outflow reads like an undeclared sale.
Double-counting fees
Fees sit inside the Luno amounts, and CARF amounts are net of fees. Deducting the fee again after using the fee-inclusive figure understates the gain against a figure SARS already holds net.
Ignoring the currency question
If you convert at a Rand average rate for the year and the provider used the value at the time of each transaction, your figure and the CARF figure will never tie. Neither approach is wrong on its face, and there is no published SARS method for crypto conversions, so document what you did and why.
What are the penalties, and does the VDP help before CARF data lands?
Two penalty regimes matter here. Administrative non-compliance penalties are levied under section 210 of the Tax Administration Act, with fixed amounts ranging from R250 up to R16 000 a month for each month non-compliance continues, recurring for a maximum of 35 months. Understatement penalties are set by the percentage table in section 223, where standard-case percentages range from 25% to 200%.
Where the risk actually sits
Understating base cost costs you money in tax. Understating proceeds is what exposes you to an understatement penalty on the shortfall. That asymmetry is worth remembering when you are tempted to file a rounded estimate.
The narrowing window
PwC’s Kyle Mandy and Kobus Dreyer have written that CARF does not create new tax liabilities but significantly expands SARS’s ability to verify whether existing obligations were correctly reported, describing a narrowing window to address past omissions. Advisers are pointing taxpayers with undeclared crypto toward the Voluntary Disclosure Programme before CARF data reaches SARS, on the basis that disclosure made before a formal investigation may mitigate penalties and reduce prosecution risk. We have not verified the governing sections of the Act for the VDP, so treat any section number you see quoted with caution and get the application assessed on your own facts. SARS has also established a dedicated Crypto Revenue Augmentation Unit, and the Draft Guide addresses circa 5.8 million taxpayers involved in crypto activity.
Do you have to give Luno your tax number for CARF?
CARF requires service providers to collect users’ jurisdictions of tax residence and taxpayer identification numbers, along with those of beneficial owners or controlling persons, as summarised in published guidance on the framework. Under the rules incorporated into South African law by Notice R.6887, a provider may suspend or terminate a customer relationship, or refuse to effectuate a relevant transaction, where a required self-certification is not provided.
Has Luno issued self-certification requests yet?
The requirement flows from the regulation and applies to licensed providers generally, so Luno users should expect the same request and complete it when it arrives. We walked through the form itself, as it appeared on another exchange, in CARF self-certification: the tax residency form.
What if your residency is unclear?
Self-certifying the wrong jurisdiction sends your aggregates to the wrong revenue authority, which is not a problem you want to unwind. Read tax residency in South Africa before you complete anything, and get the position confirmed if you have spent significant time abroad.
Do You Need Help With Luno SARS Reporting 2026?
Rebuilding a Luno history into a defensible disposal schedule takes longer than most people expect, and the decisions you make about conversion rates, base cost method and revenue versus capital are the ones SARS will test later. If you would like us to look at your own Luno exports and your 2026 ITR12 position before the 23 October 2026 deadline, book a call with us. Questions can go to info@chconsulting.co.za, and our summary of Filing Season 2026 deadlines is worth a read first.
