Building Public Trust Through Tax Reporting

Welcome to the 11th edition of Building Public Trust Through Tax Reporting.

In this year's publication, we look at why tax, risk, and sustainability sometimes speak different languages within the same organisation, and what that means for the Johannesburg Stock Exchange (JSE) Top 100 as expectations for transparency continue to rise. Drawing on our review of this year's disclosures, we examine the gap between the Chief Risk Officer (CRO), Chief Sustainability Officer (CSO), and Tax Director, and consider what it takes to bring those perspectives together into a single, coherent story.

That gap is often hidden. 

A tax position can clear the Tax Director’s technical threshold, sit untested on the CRO’s risk register, and quietly undercut the CSO’s public sustainability claims, without anyone being wrong, or even noticing. Viewed in isolation, each disclosure may make sense. Read together, however, they can tell a different story. 

That risk is now real. 

Tax authorities are already using AI to scrutinise filings in real time, and investors and analysts are applying the same scrutiny to public disclosures. Organisations that still view tax, risk, and sustainability through separate lenses are likely to be the last to spot when their story no longer adds up.

Against this backdrop, we examine how companies are responding to an increasingly complex tax environment. We analyse early disclosures under new regimes, including the first wave of reporting under Pillar Two, the Organisation for Economic Co-operation and Development’s (OECD) global minimum corporate tax framework, which introduces a 15% minimum effective tax rate for large multinational groups. We also consider the progress being made in Total Tax Contribution (TTC) disclosure and voluntary Country-by-Country Reporting (CbCR), providing insight into how businesses are navigating an increasingly complex environment. These comparisons help place individual disclosures in context, enabling organisations to understand how their approach compares with those of their peers and competitors. Our research continues to show that there is no ‘one-size-fits-all’ approach. Businesses preparing to report in the coming years should focus on sharing information that’s consistent, clear, and useful to stakeholders. As transparency expectations continue to evolve, companies that invest in connected, narrative-rich reporting will be better placed to build trust, meet stakeholder expectations, and respond confidently to a rapidly changing global tax landscape.

If you’d like to talk about your tax reporting or request your personalised tax transparency report to compare your approach with your peers, we’d be glad to continue the conversation with you. 

Throughout this report, look out for our “Judges' Perspective”. These are independent views of this year's judging panel on the themes explored throughout the publication.

Key findings

Our review of the top 100 JSE-listed companies by market capitalisation shows where South African companies stand on the journey toward greater openness, stronger governance, and a single, coherent tax story.

Deeper dive into overall performance

^{Graph 1: Overview of average transparency in South Africa per category of the framework – all companies [1].}

In 2025, 12 companies scored above 60% for overall tax transparency (2024: 12). This group includes 8 primary-listed and 4 secondary-listed entities. Meanwhile, 68 companies (2024: 65) scored 30% or less, indicating that transparency remains a challenge for most of the market.

^{Graph 2: The minimum, average, and maximum scores (out of a possible 80 points) for total tax transparency across various sectors. It highlights how companies within each sector perform relative to one another, offering a comparative view of disclosure practices.}

On average, the energy, utilities, and resources sector demonstrated the highest levels of tax transparency. Of the top 20 performers, 11 companies are from the energy, utilities, and resources sector, four from the financial services sector, four from the technology, media, and telecommunications sector, and one from the industrial manufacturing and automotive sector.

^{_{[1] From this edition onwards, we have aligned our category structure with PwC’s Global Tax Transparency and Tax Sustainability Reporting Study methodology, to enable more consistent benchmarking between South African and global results. While the underlying criteria assessed remain substantively similar, category names and the grouping of criteria within them have changed. However, the overall average score remained unchanged from the previous year. Where comparison was possible based on matching criteria we showed 2024 numbers.}}

^{_{[2] Full CbCR data refers to the complete OECD BEPS Table 1, which provides jurisdiction-by-jurisdiction on key financial and tax indicators.}}

Three functions. Three lenses. One tax position

Last year’s report focused on the shift brought about by the King V^TM Report on Corporate Governance for South Africa, 2025 (King V)^TM. Tax transparency is no longer simply about informing stakeholders of documented policies and robust controls. It is about explaining how tax decisions contribute to ethical culture, performance, conformance, and legitimacy, and how they create value for the organisation and its stakeholders. 

In previous publications, we’ve also looked at the practical challenges of tax reporting, particularly the difficulty of working across teams to ensure tax is clearly reflected in the broader value creation narrative. This year, we turn to a related issue that often receives less attention but can have an even greater impact: limited alignment between the CRO, CSO, and Tax Director. Risk, strategy, governance, and value creation should tell one coherent story, not three disconnected ones.

Each leader has a clear objective and delivers it well: risk is managed, sustainability targets are reported, and tax is compliant. Yet when tax, risk, and sustainability are considered through separate lenses, organisations can develop blind spots, inconsistent data, and exposure to regulatory challenges. The three functions rarely use the same language when discussing how tax affects risk exposure or sustainability performance.

There are usually no obvious warning signs at first. Instead, they emerge later through disclosures that do not align, tax positions that sit uneasily alongside stated risk appetite, or sustainability metrics that overlook tax altogether. With each leader focused on their own responsibilities, ownership of bringing these perspectives together can remain unclear. The gap may persist quietly for years, only to surface as a credibility issue when stakeholders start asking questions.

A new age of scrutiny driven by AI changes the stakes

Why it matters now: Stakeholders and regulators increasingly analyse disclosures together 

As reporting shifts from periodic disclosure to continuous compliance, there is little room to correct the story after the fact—data accuracy has to be right from the start, with a clear audit trail behind it. That responsibility can no longer sit with the tax function alone.

Our research shows that corporate disclosures are rarely read in isolation and AI is embedded in this process. The goal is never just to read a report—it's to inform a decision. The only defensible stance is to be clear and consistent about strategy, performance, and trade-offs. 

Investors already combine financial statements, sustainability disclosures, and investor communications with external inputs, including analyst reports, credit ratings, ESG scores, and other third-party data. Tax authorities are moving the same way: the OECD's Inventory of Tax Technology Initiatives shows over 70% now use AI to manage compliance and taxpayer services—often assessing risk before a return is filed.

Room to grow: Tax risk disclosure 

Tax appears in risk reporting, but depth is inconsistent

Depth of disclosure varied widely across the companies we reviewed.

What did this year’s study find?

• 52 (2024: 48) companies explained how they identify, manage, and monitor tax risk. 
• Of these, 17 (2024: 10) offered only high-level commentary, while 35 (2024: 38) went further—describing specific tax risks, setting out their risk appetite and tolerance for tax, and/or referring to recognised risk management frameworks.

So, what is the takeaway?

The headline shows improvement—but it masks a decline in the depth of disclosure that matters most. More companies are naming tax as a risk, but the quality of that engagement isn't keeping pace. Closing the gap between naming a risk and genuinely explaining it will be critical to meeting stakeholder expectations.

An open door: Tax in sustainability

Tax appears in sustainability reporting only rarely

^{Graph 3: Tax strategy publication rates across various sectors [3].} 

_{^{[3] Sector sample sizes vary considerably, from 2 companies (Industrial Manufacturing and Automotive) to 42 companies (Financial Services). Percentages for sectors with small sample sizes — particularly Industrial Manufacturing and Automotive (n=2) and Health Industries (n=3)—should be interpreted with caution, as individual company results can shift these rates substantially and may not be representative of broader sector trends.}}

Publishing a tax strategy is only the first step. The real test is whether that strategy connects to anything beyond itself.

What did this year’s study find?

• 47 companies published a tax strategy in 2025—down slightly from 49 in 2024.
• Fewer than 30% connected their strategy to sustainability objectives, and fewer than 20% addressed tax within sustainability reporting frameworks at all.
• Only one company provided the detailed, quantified analysis that stakeholders increasingly expect, given tax’s role in funding public services, supporting the climate transition and underpinning broader ESG commitments.

So, what is the takeaway?

• Publication rates ranged from roughly a quarter to more than two-thirds of companies, depending on the sector. This suggests that regulatory exposure, stakeholder pressure, or reporting maturity, rather than a consistent market-wide approach, are driving this variation. 
• Publishing a tax strategy is no longer the differentiator—connecting it to sustainability is. For most companies, tax still sits outside the sustainability lens, leaving a gap between compliance and the credible, connected account stakeholders now expect.

Present, but not connected

Taken together, these findings reveal a consistent pattern. Organisations are increasingly willing to talk about tax as a risk, and many now publish tax strategies. Yet few connect those disclosures to risk appetite, sustainability commitments, or broader value creation.

The issue is not that organisations lack information. The issue is that the same information is being viewed through separate lenses—and no one is responsible for bringing those views together.

This year, we asked why that gap persists. The answer starts with who's actually in the room.

Who owns what?

Picture the CRO, the CSO, and the Tax Director sitting around the same table, each asked the same simple question: “Is tax a risk your business needs to manage?” 

Chances are that you'd hear three different answers. The disconnect is not caused by poor governance. It arises because three leaders are looking at the same issue from three different perspectives.

A tax position can pass the Tax Director's technical threshold, sit untested against the CRO's formal risk register, and still undermine the CSO's public sustainability narrative. What appears acceptable through one lens may create concerns through another.

Same data, different language

The disconnect between the CRO, CSO, and Tax Director isn't about disagreement—it's about how the information is framed. Tax information, read from different vantage points, produces different conclusions, priorities, and disclosures. What follows shows what that looks like in practice.

Warning signs seen through different lenses

Different perspectives do not always produce conflicting conclusions. More often, they create gaps. Certain issues may appear important to one function but remain largely invisible to another. The following warning signs illustrate where these gaps commonly emerge.

Pillar Two in practice: South Africa’s first wave

Nowhere is this more visible right now than in Pillar Two reporting. While the warning signs above can feel abstract until they’re tested, Pillar Two reporting gives you real, current data on how prepared—or unprepared—companies are when a major global tax reform lands.

Pillar Two provides a practical example of how tax, risk, and sustainability perspectives converge around the same issue. It therefore offers a useful test of how effectively organisations connect these different perspectives in practice.

This review covers the first wave of Pillar Two top-up tax disclosures across the JSE Top 100 and mirrors similar first-wave reviews conducted internationally. As with those global peers, this first reporting cycle is an early indication of readiness rather than a final verdict on transparency.

Taken together, these warning signs highlight a clear reality: tax runs through almost every business decision you make. When you overlook it in a restructuring, a financing structure, a market expansion, or an intercompany transaction, it tends to resurface later as a risk on the CRO’s register, a challenge to the CSO’s sustainability story, or both.

Two lenses. One decision

Once you spot a warning sign, the practical question is clear: how should you assess it? The examples above show why tax cannot be judged through a single lens.

This aligns with double materiality. Both questions matter. Financial materiality highlights how tax affects earnings, cash flow, and enterprise value. Impact materiality highlights how tax decisions affect stakeholders, society, and long-term trust.

Organisations that focus on only one of these perspectives risk missing a significant part of the picture. King V^TM requires boards to hold both views simultaneously. This is integrated thinking. No decision taken to protect near-term earnings should quietly undermine the organisation’s long-term licence to operate, and vice versa.

TTC and CbCR in practice:

TTC and CbCR offer a practical way to bring these two perspectives together with clear numbers and informative data. Both help set out the full economic footprint of your business—not only the tax expense in the income statement, but the taxes you bear and collect across the value chain, and where you create that value. This is how you close the gap between what you pay and what you say.

What did this year’s study find?

The data shows these disclosures are still the exception, not the norm.

• 81 companies (2024: 84) disclosed no CbCR data at all, and only 8 published a full OECD BEPS Table 1, the most complete and comparable format.

Recognising the gap between the CRO, CSO, and Tax Director is the easy part. Closing it is where the work starts.

South African organisations already have access to extensive guidance through King V^TM, GRI 207, and the JSE Sustainability and Climate Disclosure Guidance. Yet our findings suggest that frameworks alone do not create integration. The challenge is not understanding what to disclose but ensuring that different functions use the same information to answer the same questions.

So, what can organisations do next?

Closing this gap does not require a new framework, standard, or reporting obligation. It requires organisations to recognise that tax, risk, and sustainability are increasingly different views of the same issue. 

The organisations building trust most effectively will not necessarily be those disclosing the most information. They will be those connecting information most effectively. 

In an environment shaped by AI, growing stakeholder scrutiny, and rising transparency expectations, the challenge is no longer disclosure. 

The challenge is integration. 

Each year, our independent judging panel commends companies with a primary listing on the JSE that demonstrate the highest level of tax transparency, based on the PwC Tax Transparency Framework. The companies recognised here delivered strong, consistent, and comprehensive reporting across all categories of the Framework and addressed most of its criteria.

We extend our sincere thanks to the judging panel for their time, expertise, and commitment to this initiative. Their independent assessments and thoughtful feedback continue to drive progress in transparency and accountability. 

Below we present the panel’s findings, along with some insightful comments made by them.

The PwC Tax Transparency Framework

Many organisations consider their tax disclosures in terms of “for whom and for what purpose” they are reporting—moving beyond a tick-the-box approach. There is no right way to do this. What works depends on a company’s geography, sector, and other factors. Different businesses will come to different conclusions about what to disclose and when, all in the name of building trust.

Our goal is to help companies navigate the complexity of tax transparency and turn it into something practical. With this in mind, we closely monitor developments in voluntary tax reporting and regularly update the framework to stay aligned with global frameworks and best practice. We also ensure that our criteria are clear, consistent, and comparable. This year, we have taken a further step in that alignment by adopting the same four category structure used in PwC's Global Tax Transparency and Tax Sustainability Reporting Study.

We assessed the companies’ tax disclosures to determine if they met the criteria outlined in the Framework. The criteria are organised into four main categories: 

• Approach to Tax.
• Tax Governance and Risk Management.
• Tax Numbers and Performance.
• Total Tax Contribution and the Wider Impact of Tax.

The Framework is aligned with several leading external standards and guidelines:

• GRI 207: Tax 2019.
• The tax portion of the S&P Corporate Sustainability Assessment (CSA).
• The OECD Guidelines for Multinational Enterprises.
• The World Economic Forum’s (WEF) Stakeholder Capitalism Metrics on tax.
• The EU Minimum Safeguards on taxation.

In this publication, we share the results of our review of the top 100 JSE-listed companies by market capitalisation as of 31 December 2025, using the Framework as the basis for our review. 

We conducted a comprehensive review of all publicly available information for the companies included in our analysis. This covered annual reports, tax reports, sustainability reports, company websites, and other relevant public information on tax. We also used AI-enabled tools to help identify, extract, and assess relevant disclosures—improving the consistency and efficiency of the review process. While we aimed to include all relevant public data, our sources may not be exhaustive.

We hope this report is a useful tool for companies developing their tax transparency narrative and preparing for new global standards and regulatory disclosures.

If you’d like to explore ways to enhance your tax reporting and governance, we are here to help. On request, we can provide high-level feedback reports that benchmark your company’s voluntary tax disclosures against your peers.