Revenue Laws Amendment Act: Two-Pot System Date Correction

Posted 24 December 2025 Written by Acts Online
Category Tax Law

Brought to you by SA Legal Academy: The Revenue Laws Amendment Act, 2025 has been signed into law to correct a commencement date discrepancy affecting the implementation of the two-pot retirement system.

In terms of the Revenue Laws Amendment Act, 2025, which was passed by Parliament in October 2025 and subsequently gazetted, the National Treasury has addressed a specific starting date anomaly originally contained in the Revenue Laws Amendment Act, No. 12 of 2024. This correction is required to provide a firm legal basis for the calculation of opt-in seed capital.

The amendment focuses on the technical alignment of dates for the transition to the three-component retirement framework, which includes:

  • The savings component, allowing for pre-retirement access;
  • The retirement component, which must be preserved until retirement; and
  • The vested component, containing all savings accumulated prior to the implementation date.

The correction ensures that fund administrators can accurately calculate the seed capital—the initial amount transferred from the vested component to the savings component—without the risk of administrative or legal challenges arising from the previous date anomaly in the 2024 statute.

What this means for you, your business, or your clients

  • For yourself: No direct individual filing obligations; however, you should verify that your retirement fund statement reflects the corrected commencement date for any seed capital transfers.
  • For your business: Compliance officers and payroll managers must ensure that internal benefit systems and third-party fund administrators have updated their calculation logic to align with the 2025 Act’s corrected timeline.
  • For your clients: Tax practitioners and financial advisors should review client portfolios to ensure that seed capital allocations made during the transition to the two-pot system comply with the revised statutory dates to avoid future SARS reconciliation issues.

Originally published at https://legalacademy.co.za/news/read/revenue-laws-amendment-act-2025-joins-statute-books

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