Businesses and individuals in Eswatini will no longer be able to carry forward unresolved tax obligations while continuing to transact, following the Eswatini Revenue Service’s (ERS) firm enforcement of the Tax Compliance Certificate (TCC) Regulations.
Speaking at a Tax Compliance Certificate (TCC) Briefing Session at ERS headquarters on Monday, Commissioner General Brightwell Nkambule and Minister of Finance Neal Rijkenberg made it clear: without a valid TCC, several key economic transactions will not proceed.
The renewed enforcement drive comes days after the presentation of the 2026/27 National Budget, which set a domestic revenue target of E19.48 billion. “This is not an assignment for the ERS alone. It is an assignment for the entire nation,” Nkambule said, underscoring that compliance is central to funding national development and safeguarding the country’s fiscal stability.
Under the Regulations, no person or business will be permitted to proceed with the following transactions without a valid Tax Compliance Certificate.
• Renewal or transfer of a trade licence or business permit.
• Transfer of immovable property.
• Registration or deregistration of a company.
• First registration of a motor vehicle.
• Registration of a second-hand motor vehicle.
• Tendering for goods or services exceeding E20,000.
• Purchase, sale, or transfer of shares.
• Renewal of temporary residence permits.
• Performance by non-resident entertainers or sportspersons.
• Registration for the importation of goods.
• Transfer of funds offshore through financial institutions.
• Furnishing of a tax compliance certificate where required by law or policy.
• Distribution of a deceased estate.
Compliance Checkpoint
Compliance at these transaction points effectively establishes what Nkambule described as a “compliance checkpoint” across the economy. “If a taxpayer fails to meet obligations in one period, they will not receive a Tax Compliance Certificate to conduct the next regulated transaction unless they regularize their position,” he explained.
In practical terms, non-compliance cannot be rolled forward indefinitely while business continues as usual.
The enforcement initiative comes amid an estimated E4 billion annual tax gap, according to the Minister of Finance. Authorities say some businesses fail to register, file nil returns despite visible activity, underreport income, or accumulate tax debt before closing and reopening under new entities.
To curb this, financial institutions will now play a more direct role in verifying tax compliance, particularly for cross-border fund transfers. For transfers outside the Common Monetary Area (CMA), compliance verification will occur before processing. For CMA transfers, verification will initially occur after the transaction.
“Our objective is not disruption. Our objective is integrity,” Nkambule emphasized.
Banking Sector Fully Behind ERS
The banking industry has publicly aligned with the new enforcement measures. Speaking at the briefing, Fikile Nkosi, Chairperson of the Eswatini Bankers Association, described tax compliance as both a national and a financial priority.
“Tax compliance and cross-border transactions supporting ERS and safeguarding the financial system are priorities for us if we are to exist and continue sustainably,” Nkosi said.
She explained that the ERS has enhanced, rather than introduced, tax clearance requirements for cross-border transactions, thereby tightening existing controls to eliminate loopholes.
“These measures are part of broader efforts to strengthen revenue collection, transparency, and system integrity,” she noted, adding that this regulatory tightening is not unique to Eswatini but reflects a global trend in which revenue authorities are strengthening oversight of cross-border financial flows to combat tax evasion and illicit financial activity.
Nkosi acknowledged concerns in the business community, particularly regarding transactions with South Africa, Eswatini’s largest trading partner. Given the high volume of trade between the two countries, tax clearance is now a critical prerequisite for cross-border payments, including those with South Africa.
“As a business community, we are very concerned about compliance in that particular economy because we trade a lot with South Africa,” she said.
She, however, assured stakeholders that fully compliant transactions will continue to be processed, subject to verification. Nkosi acknowledged that the enhanced requirements have been perceived as inconvenient by some taxpayers, but emphasized that ongoing engagements between banks and ERS aim to ensure that lawful transactions are not unnecessarily delayed.
“The last thing you want is for a good, compliant taxpayer to be bundled together with everybody else in the queue,” she said.
According to Nkosi, the Bankers Association has been meeting with ERS, including engagements as recent as last week, to clarify operational processes, reduce unintended delays for compliant clients, and balance compliance with ease of doing business.
“Our objective is balanced compliance with ease of doing business. This is a partnership approach, with industry, regulators, and clients working together,” she said.
She urged businesses to: remain compliant and regularly check their tax status; maintain a valid Tax Compliance Certificate; use ERS digital platforms and applications to verify compliance; engage early with ERS or their bankers if challenges arise; and seek tax advisory services where necessary.
“Compliance is not a barrier; it is a foundation for sustainable economic growth,” Nkosi emphasized. She added that banks have both legal and ethical obligations to prevent the financial system from being used as a conduit for tax evasion, in line with anti-tax evasion regulations.
“Our role is not to police taxpayers but to ensure the financial system is not abused,” she said.
Minister Rijkenberg underscored that enforcement is deliberately structured as a shared responsibility across the economy. Financial institutions must require a valid TCC before processing international transfers. Procuring entities in the public and private sectors must insist on compliance before awarding contracts above E20,000. Licensing and registration authorities must verify compliance before completing designated transactions.
“Enforcement is not confined to one institution; it is embedded in key economic transaction points throughout the economy,” Rijkenberg said.
He stressed that the Regulations do not introduce new taxes or penalize honest businesses, but rather protect compliant enterprises from unfair competition by those who evade tax obligations.
Although the Regulations became effective in December 2022, ERS delayed full enforcement to simplify processes, digitize the system, and allow taxpayers time to regularize their affairs. The TCC application system is now fully digitized and accessible 24 hours a day, with verification platforms available to authorized institutions.
The Minister argued that stronger compliance would reduce reliance on borrowing, thereby shielding future generations from the burden of servicing today’s fiscal deficits. “When Government borrows, tomorrow’s taxpayers repay with interest,” he said, urging collective responsibility to close revenue gaps.