UAE–Africa Legal & Regulatory Briefing: 15–20 September 2026

Top Priorities This Week

1. South Africa — prepare for the new diesel-refund system. Transitional customs rules took effect on 18 September, although the operational start date remains to be announced.
2. South Africa — review consumer-facing labels, pricing and receipts. Draft nationwide guidelines cover physical and online sales; comments are due approximately 2 November 2026.
3. Month-end deadlines are approaching. UAE corporate-tax filings and major South African ESG consultations close between 28 and 30 September.
4. Complete Rwanda annual filings. The extended company annual-return and accounts deadline remains 30 September 2026.

Confirmed Developments

High — South Africa: diesel-refund rules amended

Relevant date: 18 September 2026

Instrument: Customs and Excise Amendment Rules DAR280

Status: Transitional provisions effective; full implementation deferred

SARS introduced the legal framework for its new electronic diesel-refund scheme. Applications and registrations will use SARS eFiling and the Business Front End, while participant information will include powered assets, storage tanks, locations and relevant commercial relationships.

Applicants must have their tax affairs in order. Disclosed relationships with sellers, contractors, transporters, asset lessors and other refund users generally require confirmation by the counterparty within seven working days.

The core operational provisions will commence on a date still to be announced by the Commissioner. Approval before that date will not permit refund claims.

Official source

Practical implications: Mining, agriculture, forestry and other eligible users will require substantially cleaner asset, fuel-use and counterparty data. Sellers and contractors may also need systems for confirming relationships promptly.

Principal risks:

• Rejected or delayed refunds because counterparties do not confirm relationships;
• Inconsistent asset, location, invoice or fuel-delivery records;
• Application failure due to outstanding returns, tax or penalties;
• Cash-flow disruption during migration to the electronic regime.

Actions:

• Clear outstanding tax returns and liabilities.
• Inventory powered assets, tank capacities, identifiers and GPS locations.
• Reconcile fuel suppliers, transporters, contractors and leasing arrangements.
• Add seven-working-day confirmation obligations to relevant contracts and procedures.
• Preserve sales, duty, delivery and transport records for at least five years.
• Monitor SARS for the application window and operational commencement date.

Proposals and Consultations — Not Yet Fully in Force

High — South Africa: proposed consumer labelling, pricing and sales-record guidelines

Published: 18 September 2026

Comment period: 45 days; approximately 2 November 2026

The National Consumer Commission published draft guidelines covering manufacturers, importers, distributors, wholesalers, retailers and service providers across stores, e-commerce platforms, mobile commerce and informal trading.

Official source

The proposals address:

• Accurate, plain-language product descriptions;
• Quantity, composition, origin, expiry, storage and GMO disclosures where applicable;
• Clearly displayed prices in rand, including VAT and mandatory charges;
• Upfront disclosure of booking, service and administration fees;
• Transaction records identifying the supplier, VAT number, products, quantities, prices, taxes and total amount.

The draft contains an apparent status ambiguity: it invites public comments but also states that the guidelines take effect on Gazette publication. Businesses should therefore treat the stated standards as immediate compliance expectations while seeking clarification on final legal status.

Practical implications: Imported goods, online storefronts, checkout processes and point-of-sale receipts may require modification.

Principal risks: Compliance notices, administrative penalties, product recalls, prosecution, consumer refunds and disputes over hidden or incorrectly displayed charges.

Actions:

• Audit product pages, labels, price displays and checkout flows.
• Confirm prices include VAT and unavoidable charges.
• Remove pre-selected or late-disclosed fees.
• Test receipts against the proposed mandatory fields.
• Review country-of-origin and importer information on foreign products.
• Consider submitting comments before the 45-day period expires.

Urgent — South Africa: outstanding ESG and professional-regulation consultations

• 28 September, 12:00 — Revised Electricity Pricing Policy. Stress-test tariffs, network charges and wheeling economics; submit comments where exposure is material. Source
• 30 September, 12:00 — Industrial minimum-emission standards. Quantify compliance CAPEX and review environmental warranties, licences and transaction valuations. Source
• 30 September — IRBA proposed competency framework. Complete recruitment, training, assessment and quality-management gap analysis. Source

Deadline Watch

• 28 September — UAE: VAT return and payment for applicable tax periods.
• 28 September — South Africa: Electricity-pricing-policy comments.
• 30 September — UAE: Corporate-tax return and payment for taxpayers with a 31 December 2025 year-end. FTA source
• 30 September — Rwanda: Extended company annual returns and accounts.
• 30 September — South Africa: Air-quality and IRBA consultation submissions.
• Approximately 2 November — South Africa: Consumer-guidelines comments.

Cross-Jurisdictional Themes

• Structured data is becoming a condition of regulatory access: Tax relief and licensing increasingly depend on accurate asset, location, ownership and counterparty records.
• Counterparty compliance affects entitlement: South Africa's diesel regime illustrates how a supplier's or contractor's failure to confirm information can disrupt another party's claim.
• Online commerce receives the same scrutiny as physical retail: Pricing, labelling and receipt controls must operate consistently across channels.
• ESG exposure is financial exposure: Electricity pricing and emissions standards should be incorporated into contracts, valuations, financing models and M&A due diligence.

No other consequential new measure was verified from accessible official sources during this review period for the UAE, Kenya, Uganda, Tanzania, Rwanda, Ethiopia, Mauritius, Nigeria, Ghana or Liberia. Existing compliance calendars remain applicable.

Practical Action Checklist

• Map South African diesel-refund entities, assets and counterparties.
• Resolve outstanding SARS returns and liabilities.
• Establish a rapid process for confirming diesel-scheme relationships.
• Audit South African product labels, online prices, fees and receipts.
• Complete UAE corporate-tax returns before the final days of September.
• Finalise South African electricity, emissions and audit-framework submissions.
• Complete Rwanda annual returns and supporting statutory records.
• Add counterparty data-confirmation duties to relevant contracts and compliance procedures.

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Disclaimer

This briefing is provided by AMADI Legal Consultancy for general information only and reflects developments identified during the stated review period from accessible official sources. It does not constitute legal advice, create a lawyer–client relationship, or account for the facts of any particular matter. Regulatory positions, deadlines and instruments may change or be superseded. Before acting on any item, obtain specific advice on your circumstances and confirm the current position with the relevant regulator or official source.