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 hold the CBAP(SA) designation as a Practising Member of the Southern African Institute of Business Accountants and the GTP(SA) designation as a Practising Member of the South African Institute of Tax Professionals. 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.
| Period or event | CARF position | Status |
|---|---|---|
| 2026 ITR12 (1 Mar 2025 to 28 Feb 2026) | No CARF data exists | Outside CARF |
| 2027 year (1 Mar 2026 to 28 Feb 2027) | Aggregates due at SARS 31 May 2027 | Reconciliation exposure |
| Exchange with foreign authorities | First exchange September 2027 | Date published |
| Pre-population of the ITR12 | Not stated by SARS | 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.
Whether CARF will pre-populate the 2027 return is unsettled
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, the sequencing is genuinely unclear.
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. We could not locate an Interpretation Note or a Binding General Ruling on crypto assets, so there is nothing binding to point at either way.
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?
We have not been able to confirm any Luno announcement on self-certification, so we are not going to assert one. What we can say is that the requirement flows from the regulation and applies to licensed providers generally. 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 genuinely 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.
Where these rules come from
- SARS: Crypto Asset Reporting Framework (CARF) sets out the first reporting period, the 31 May 2027 submission date and the September 2027 exchange date.
- Notice R.6887, Government Gazette 53735 is the Ministerial regulation issued under sections 1 and 257 of the Tax Administration Act that brings CARF into South African law.
- SARS: Crypto Assets and Tax explains the revenue versus capital distinction and the Eighth Schedule treatment.
- OECD CARF XML Schema defines the Amount element net of fees and the six-decimal unit reporting that the SARS BRS implements.
- SARS media release, 18 June 2026 confirms the auto-assessment window and the 13 July to 23 October 2026 filing period.
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.
Frequently Asked Questions
Does Luno report to SARS?
Under CARF, licensed South African crypto asset service providers report certain crypto asset transaction information to SARS, and Luno (Pty) Ltd appears on the FSCA’s published list of authorised CASPs with FSP number 53314. The obligation rests with the provider, not with you.
What does Luno actually send SARS under CARF?
Per crypto asset, the aggregate gross amount paid and received, the aggregate number of units and the number of transactions, split between acquisitions and disposals. It is an annual summary with a transaction count, not a trade-by-trade ledger.
What tax year does CARF cover in South Africa?
The first CARF reporting period runs 1 March 2026 to 28 February 2027, which corresponds to the 2027 year of assessment. The 2026 ITR12 you are filing now covers 1 March 2025 to 28 February 2026 and predates CARF.
When does SARS actually receive the first Luno CARF report?
The CARF return for the first reporting period must be submitted to SARS by 31 May 2027, and the first exchange of CARF information between participating jurisdictions takes place in September 2027.
Will my Luno trades show up on my 2026 auto-assessment?
Not from CARF, because no CARF data exists for that year. If you had disposals and your auto-assessment is silent on them, the omission remains your responsibility to correct.
Do I have to declare crypto if I never withdrew to my bank account?
SARS’s position is that normal income tax rules apply to crypto assets and that gains or losses must be declared as part of taxable income. A disposal can happen without any Rand ever reaching your bank account.
Is swapping BTC for USDC on Luno a taxable event in South Africa?
SARS generally treats a disposal as a disposal regardless of what you receive, and CARF reports both legs of a crypto-to-crypto exchange with unit counts. The Draft Guide addresses swaps but is expressly not a binding general ruling, so confirm the treatment against your own facts.
Does Luno issue an IT3(b) or IT3(c) for SARS?
We have seen no indication that Luno issues either, and Luno has said it does not provide tax certificates. You reconstruct the figures from wallet statements yourself.
How do I download my Luno tax statement for SARS?
Go to Wallets, select the wallet, choose Download Statement, set the begin and end dates, select CSV, then Create Statement and Download. Repeat for every wallet, and unzip the file Luno delivers.
How do I export all my Luno wallets to CSV?
There is no single account-wide export; the statement download is per wallet. List every wallet you have used, including savings wallets, and tick them off as you export, because a missed wallet removes an entire asset from your calculation.
Which source code do I use for crypto profit on the ITR12, 2572 or 6520?
Code 2572 was recorded for crypto assets profit on revenue account and 6520 for gains on local crypto financial instruments within the capital gains container. Those codes come from a 2021 document, so verify them on SARS’s current Find a Source Code tool before capturing.
Is my Luno crypto a capital gain or trading income for SARS?
SARS says the determination is tested under existing jurisprudence, and we could not locate an Interpretation Note or Binding General Ruling on crypto assets. Frequency, holding period and stated intention all matter, and the answer is fact-specific.
What is the capital gains annual exclusion for the 2026 tax year?
R40 000 applies to the 2026 year of assessment ended 28 February 2026. The increase to R50 000 takes effect from 1 March 2026 and first applies to the 2027 year.
Do I use FIFO or weighted average for crypto base cost in South Africa?
This is unsettled. SARS’s IT3(c) clarification describes crypto base cost as constituting “identical assets”, which points toward weighted average, while most consumer tools default to FIFO; pick one method, apply it consistently and document the choice.
What exchange rate do I use to convert Luno trades to Rand for SARS?
There is no published SARS method for crypto conversions. Using the rate at the time of each transaction is more likely to align with what a provider reported; using an average rate is simpler but guarantees a variance against the CARF figure.
Am I a provisional taxpayer if I trade crypto on Luno?
SARS’s crypto FAQ states that receipts and accruals from trading in crypto assets, less deductible expenses, form part of taxable income for the year for which provisional tax is payable and must be included in the amount declared on the IRP6. Whether you are registered as a provisional taxpayer depends on your full income picture.
What happens if my declared crypto figure does not match what Luno sent SARS?
From 2027 onward, expect a verification request comparing your declared proceeds against the CARF aggregates, with the onus on you to prove base cost. A documented reconciliation is what turns that from an assessment into a query.
Does SARS see when I send Bitcoin from Luno to my own wallet?
Transfers are a reportable category under CARF, so an outflow can be visible to SARS even though it is not a disposal for tax. Keep the destination address and the later disposal record together.
Is transferring crypto from Luno to a hardware wallet a disposal?
Moving your own units between wallets you control is not a disposal, because ownership has not changed. The evidential problem is proving it, which is why the destination and the eventual sale need to be documented.
Do I pay tax on Luno staking or savings wallet rewards?
Rewards are receipts or accruals in their own right, and SARS’s position is that the onus is on taxpayers to declare all crypto-asset-related taxable income in the year it is received or accrued. Staking also has its own CARF classification, CARF401.
What is the penalty for not declaring crypto to SARS?
Administrative non-compliance penalties under section 210 of the Tax Administration Act range from R250 up to R16 000 a month for each month of non-compliance, recurring for a maximum of 35 months, and understatement penalties under the section 223 table range from 25% to 200% in standard cases.
Can SARS go back and assess my crypto from previous years?
Section 46 of the Tax Administration Act allows SARS to request information about specific customers from exchanges, and AltCoinTrader, Luno and VALR confirmed in 2021 that it had done so. Prior years are not closed simply because CARF only started in 2026.
Should I use the Voluntary Disclosure Programme before CARF data reaches SARS?
Advisers are recommending the VDP as the route to regularise undeclared crypto ahead of CARF data landing, on the basis that disclosure before a formal investigation may mitigate penalties. We have not verified the governing sections, and eligibility depends on your facts, so get it assessed before you file anything.
Is the SARS Draft Guide to the Taxation of Crypto Assets binding?
No. The Draft Guide states that it is not an official publication as defined in the Tax Administration Act and is not a binding general ruling, and comment was open until 31 August 2026.
Does SARS have a binding ruling on crypto tax?
We could not locate an Interpretation Note or Binding General Ruling dealing with crypto assets. That absence is why so much of the treatment turns on general principles and on your own documented facts.
Can I claim my Luno trading losses against my salary?
Crypto asset activities appear in the section 20A “suspect trades” list, so an individual’s losses may be ring-fenced against future crypto income in certain circumstances. Whether SARS applies this systematically to crypto is not verified.
Does Luno share my information with foreign tax authorities?
SARS states that CARF information may be exchanged with other participating jurisdictions, with the first exchange taking place in September 2027. The exchange is between revenue authorities rather than directly from the platform.
Will SARS know about my offshore exchange account too, or only Luno?
CARF is an international standard and information is exchanged between participating jurisdictions, so reporting is not limited to South African platforms. What reaches SARS about any specific offshore provider depends on that provider’s own jurisdiction and obligations.
Can Luno freeze my account if I do not complete self-certification?
The rules incorporated by Notice R.6887 allow a provider to suspend or terminate a customer relationship, or refuse to effectuate a relevant transaction, where a required self-certification is not provided. We have not confirmed any Luno announcement about how it is applying this.
What is the deadline to file the 2026 ITR12 with crypto included?
The broader filing period for provisional and non-provisional taxpayers runs 13 July to 23 October 2026, with provisional taxpayers and trusts able to file until 22 January 2027.
How far back do I need Luno records for a SARS audit?
Keep every wallet export, your paired trade schedule and your method notes for as long as any year remains open to assessment, which in practice means indefinitely for assets you still hold. Base cost on a coin bought in 2019 is only provable from 2019 records.