By Chris Herbst, Chartered Business Accountant in Practice (CBAP) with CIBA, General Tax Practitioner (GTP) with SAIT, Stellenbosch University. Team registered with SAIT, SAIPA and CIBA.
Code 3828 appears on fewer IRP5 certificates than the pension and provident fund codes, which is why it raises more questions when it does appear. An employee sees an amount in the income block, recognises no payment for it, and then finds a matching figure in the deductions block next to code 4006. The two lines belong together. This guide explains what 3828 contains, how it moves into 4006 and the retirement fund deduction, what the related codes 3878 and 4475 show, and what to check on eFiling before you file.
What Does SARS Code 3828 Mean on an IRP5?
Code 3828 is the value of the taxable benefit when your employer pays contributions to your retirement annuity fund on your behalf. The SARS Guide for Codes Applicable to Employees Tax Certificates 2027 describes it as "Employer retirement annuity fund contributions paid on behalf of an employee (payment of employee's debt)", and labels the code as subject to PAYE.
Why does SARS call it an employee's debt?
A retirement annuity is a policy you own in your own name. The premium is your obligation to the fund, so when your employer pays it, the employer is settling a debt that belongs to you. That is the reason the codes guide titles 3828 "Employees Debt: Employer paid Retirement Annuity Fund contributions", while the pension and provident fund codes are described as employer contributions to the employer's own fund.
Is 3828 the same as code 3808?
No. Code 3808 is the general taxable benefit for the payment of an employee's debt or release from a debt. The codes guide titles 3808 "Employee's debt, excluding code 3828", so retirement annuity premiums your employer pays are reported under 3828 and are kept out of 3808.
From which year does code 3828 apply?
The codes guide states that 3828 is valid from the 2017 year of assessment. That follows the change described in the SARS Comprehensive Guide to the ITR12: from 1 March 2016 the employer's retirement fund contribution became a taxable fringe benefit in the hands of the employee, and that benefit in turn became a contribution deemed made by the employee.
Where can I look up the code myself?
SARS keeps a find a source code page for individuals, and the codes guide lists every IRP5 code with its description. Read the code in the income section of your IRP5 or IT3(a), then compare the description with the guide.
How Does Code 3828 Flow Into Code 4006?
The 3828 value is added to your income and the same value is counted as a retirement annuity contribution made by you. The SARS PAYE Business Requirements Specification defines code 4006 as the total retirement annuity fund contributions paid and "deemed paid" by the employee, and states that "deemed paid" is the value of the fringe benefit under code 3828 included in the employee's income.
So is 4006 larger than what came off my payslip?
Often, yes. Code 4006 includes contributions deducted from your salary and paid over by your employer, plus the employer-paid amount from 3828. Where your employer pays the full premium, the 3828 value and the 4006 value from that employer agree.
What is code 4475?
Code 4475 is the employer's retirement annuity fund contributions paid on behalf of the employee. The BRS states that the code is valid for the 2008 and 2009 years of assessment and from the 2017 year of assessment. It records the payment itself, while 3828 records the taxable value of that payment in your income.
Which codes must appear together?
The BRS validation rules state that if code 4475 is completed, then code 3828 and/or 3878 and code 4006 must be completed. An IRP5 that shows 4475 without 3828 or 3878, or without 4006, does not meet the SARS specification and goes back to your employer for correction.
- 3828: What it shows: Employer-paid RA benefit; Where it sits: Income
- 3878: What it shows: Same benefit, foreign service; Where it sits: Income
- 4475: What it shows: Employer RA payment; Where it sits: Employer contributions
- 4006: What it shows: Total RA paid and deemed paid; Where it sits: Deductions
- 3808: What it shows: Other employee debts paid; Where it sits: Income, excludes 3828
What Is Code 3878 and When Is It Used Instead?
Code 3878 is the foreign service twin of 3828. The codes guide states that 3878 is used only for the taxable benefit of employer contributions to a local fund while the employee is on foreign service, and that it is valid from the 2017 year of assessment.
Can I have both 3828 and 3878 on one certificate?
The BRS rule reads "3828 and/or 3878", so a certificate can carry either or both. Where part of the year was spent on foreign service, the employer splits the benefit between the two codes, and 4006 carries the total contribution either way.
Does 3878 change how the deduction works?
No. Both codes create a deemed contribution that is counted in 4006. What differs is how the underlying income is reported, which is why the foreign service codes exist alongside the local ones.
Does Code 3828 Mean I Pay More Tax?
Code 3828 increases your income by the value of the premium your employer paid, and the same amount then counts towards your retirement fund deduction. Where your total contributions fall inside the limit in section 11F of the Income Tax Act, the deduction offsets the benefit and the net effect on your taxable income is nil.
What is the retirement fund deduction limit?
The ITR12 guide states that the allowable deduction is the lesser of R350,000 for years of assessment up to 2026 and R430,000 from the 2027 year of assessment; 27.5% of the greater of your remuneration or your taxable income (including taxable capital gains, before the section 11F and 18A deductions); and your taxable income before those deductions excluding taxable capital gains. Lump sum and severance benefits are left out of each measure.
Which contributions share the limit?
The one limit covers pension fund (4001), provident fund (4003) and retirement annuity (4006) contributions together. Our guide to retirement fund deductions and the 27.5% cap works through the calculation in more detail.
What happens to contributions above the limit?
The ITR12 guide states that SARS calculates the allowable deduction programmatically and carries any excess forward to the following year of assessment, where it is taken into account in that year's calculation.
How Is Code 3828 Different From 3817 and 3825?
The three codes carry the same kind of taxable benefit for three types of fund: 3817 for a pension fund, 3825 for a provident fund and 3828 for a retirement annuity fund. The ITR12 guide lists them together, and each has a matching deduction code: 4001, 4003 and 4006.
Where do I read about 3817 and 3825?
Our guides to SARS code 3825 for provident funds and code 4472 for employer pension contributions cover the employer fund side, and the ITA34 codes guide shows where all of them appear on your notice of assessment.
Why is the employer code 4475 and not 4472 or 4473?
Each fund type has its own employer contribution code: 4472 for a pension fund, 4473 for a provident fund and 4475 for a retirement annuity fund. The BRS applies the same rule to each pair, so a completed employer contribution code always needs its benefit code and its deduction code.
What If I Am a Partner in a Partnership?
The ITR12 guide has a separate question for partners. From the 2017 year of assessment a partner who is a deemed employee of the partnership indicates the fund type and completes the fringe benefit field, using 3828 for a retirement annuity fund.
What figures does the partner section ask for?
The guide asks for the name of the fund, its FSCA registration number, the policy number, the amount contributed by the partnership, the fringe benefit and the contributions made by you. The fringe benefit amount must be less than or equal to the amount contributed by the partnership, and eFiling totals each fund type into 4001, 4003 or 4006.
Do I enter the 4006 total a second time?
Yes. The guide states that the 4006 amount from the partner section must also be inserted next to source code 4006 in the Retirement Annuity Fund Contributions section to claim it.
How Do I Check Code 3828 on eFiling, Step by Step?
Check the code before you accept an auto-assessment or file your ITR12. These steps follow the eFiling screens the ITR12 guide describes.
- Gather your documents. Collect your IRP5 or IT3(a), your February payslip and the retirement annuity certificate from the fund, usually an IT3(f). Our list of documents needed to file your tax return sets out the rest.
- Open the return. Log in to eFiling, go to Returns and open the ITR12 for the year of assessment.
- Read the IRP5 section. In each IRP5/IT3(a) on the return, find 3828 or 3878 in the income block and 4006 in the deductions block. Confirm that 4006 is at least as large as the 3828 and 3878 values together.
- Mark the retirement annuity question. On the return wizard, mark with an X that you or your employer contributed to your retirement annuity benefit. This opens the Retirement Annuity Fund Contributions section.
- Check the prepopulated policies. The ITR12 guide states that from the 2020 year of assessment retirement annuity details are prepopulated from the fund's data. Confirm the number of policies and the contribution for each against your certificates.
- Complete the 4006 total. The field "Total contributions for this year assessment" (source code 4006) must be the total for all your retirement annuity policies, including the amount on your employee tax certificate. eFiling calculates it from the policy lines.
- Review the calculation. Use the calculation before you submit and confirm the retirement fund deduction is applied. After assessment, check it again on your ITA34.
What If Code 3828 on My IRP5 Is Wrong?
Your employer issued the IRP5, so your employer corrects it. Ask payroll for a corrected certificate, which the employer submits to SARS, before you file.
3828 shows an amount, but my employer did not pay my RA
The benefit belongs on your IRP5 only when your employer paid the premium. If the premium came from your own bank account, the amount is not a 3828 benefit, and you claim it from your fund certificate in the 4006 field instead.
4006 on the IRP5 is lower than 3828
4006 must include the deemed contribution from 3828, so a 4006 below 3828 on the same certificate points to a payroll error. Ask for a reissued IRP5, or lodge a request for correction once the corrected certificate is on record if you have already filed.
The prepopulated retirement annuity data is wrong
The ITR12 guide states that prepopulated retirement annuity data cannot be deleted from the return. If it is incorrect, you contact the fund to correct and resend the data to SARS. The number of prepopulated policies cannot be reduced, although the value can be increased if you have more policies to declare.
The assessment did not give me the deduction
Compare the 4006 figure on the ITA34 with your fund certificates. If a policy is missing, correct the return. If you disagree with an assessment SARS has issued, the dispute route is an objection on eFiling.
What Are the Common Mistakes With Code 3828?
Most problems with 3828 come from reading the IRP5 line on its own, without the deduction line that goes with it.
- Treating 3828 as cash income. It is the value of a premium paid for you, not money paid to you, and it is offset by the 4006 deduction within the section 11F limit.
- Leaving out the fund certificate. The ITR12 guide states that the certificate amount must be inserted next to 4006 for the deduction to be taken into account, so a return that relies on the IRP5 line alone can lose the deduction.
- Counting the same premium twice. The 4006 total covers all your policies including the employer-paid one. Adding the IRP5 amount on top of a certificate that already includes it overstates the deduction.
- Claiming a spouse's or child's policy. The ITR12 guide states that you may not claim retirement contributions made on behalf of a third party, such as a spouse or child.
- Discarding the proof. The guide requires you to keep proof of retirement annuity contributions for five years after the date you submit the return.
- Ignoring 4475 without 3828. A certificate showing the employer's payment under 4475 with no 3828 or 3878 value fails the BRS rule and needs a corrected IRP5.
How Does 3828 Fit Into Your Wider Retirement Planning?
An employer-paid retirement annuity is a salary structuring choice as much as a tax line. The benefit and the deduction travel together, so the tax outcome turns on how your total contributions compare with the section 11F limit across all your funds.
Does it matter if I also contribute to a pension fund at work?
Yes, because the R430,000 and 27.5% limits from the 2027 year of assessment apply to the combined total of 4001, 4003 and 4006. Our guide to the tax benefits of retirement annuities sets out how the limit works across funds.
Should I check this each year?
Yes. Salary changes, new policies and a change of employer all move the figures. Reading 3828 and 4006 together each filing season is the simplest check that the deduction matches what was paid.
Do You Need Help With SARS Code 3828?
If code 3828 or 4006 on your IRP5 does not agree with your retirement annuity certificates, or your assessment did not apply the deduction you expected, we check the certificates, complete the return and deal with SARS for you. See our personal tax return plans, browse more personal tax guides, or contact us to get started.
