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Importer of Record

Importer of Record in South Africa

A foreign company can be the importer of record in South Africa. SARS lets a foreign person register as an importer in its own name, provided it registers as a foreign principal and nominates a South African registered agent that accepts liability for its customs obligations; a licensed customs clearing agent then lodges the SAD 500. Where the client prefers not to hold its own South African importer registration, TFTIOR provides a locally registered importer of record instead.

TFTIOR provides a South African registered importer of record and manages the import end to end, so the client needs no local entity. Any ICASA type approval, an NRCS Letter of Authority for an in-scope electrical SKU, and any ITAC permit for used goods must be in place before the goods ship.

Last reviewed 2026-08-30

AT A GLANCE

Fast facts

Customs authority
SARS (South African Revenue Service)
Declaration / filing system
the SARS Customs system on eFiling, with the SAD 500 customs clearance declaration lodged by EDI
Importer registration
Customs registration and VAT registration are separate. The importer of record holds a SARS customs client number; VAT vendor registration is a distinct step that is needed only where the structure makes taxable supplies in South Africa, and is not a precondition for the customs client number. Under the TFTIOR local importer-of-record structure the client registers nothing in South Africa.
Import tax
VAT on importation (Value-Added Tax Act 89 of 1991) at 15% on the added tax value: the customs value, plus 10% where the goods originate outside the Southern African Customs Union, plus any non-rebated customs duty; conditional
Used / refurbished
licensed
Typical clearance (air)
1 to 3 business days for a clean shipment; a documentary stop or examination adds several days
Key product regulators
Independent Communications Authority of South Africa (ICASA), National Regulator for Compulsory Specifications (NRCS), International Trade Administration Commission (ITAC)
Local entity requirement
No South African company or branch is required. A foreign company can import under its own SARS foreign-principal registration with a South African registered agent, or it can use the locally registered importer of record that TFTIOR provides. Neither route requires the client to incorporate in South Africa.

Who can act as importer of record

Who can legally act as importer

Under the Customs and Excise Act 91 of 1964 and the SARS Registration, Licensing and Accreditation rules, any person, local or foreign, who imports goods must register with SARS as an importer. A non-resident registers as a foreign principal and must nominate a registered agent located in South Africa, on form DA 185 and its registered-agent annexure, before the registration is activated; that registered agent assumes full liability for the foreign principal customs obligations. Separately, a licensed customs clearing agent lodges the customs declaration on the importer behalf.

No South African company or branch is required. A foreign company can import under its own SARS foreign-principal registration with a South African registered agent, or it can use the locally registered importer of record that TFTIOR provides. Neither route requires the client to incorporate in South Africa.

Importer registration

Customs registration and VAT registration are separate. The importer of record holds a SARS customs client number; VAT vendor registration is a distinct step that is needed only where the structure makes taxable supplies in South Africa, and is not a precondition for the customs client number. Under the TFTIOR local importer-of-record structure the client registers nothing in South Africa.

Who carries import liability

The importer of record named on the SAD 500 carries the customs duty, VAT and regulatory liability to SARS under the Customs and Excise Act 91 of 1964. Where the client registers as a foreign principal, its South African registered agent is liable alongside it for those obligations; where the TFTIOR local importer of record is named, that entity carries the liability and TFTIOR coordinates the SARS response. SARS may reopen the entry and raise a demand for underpaid duty or VAT, and the importer keeps the entry records for five years. The client remains responsible for product data accuracy and end-user truthfulness.

Importer of record compared with the alternatives

Two structures are available. First, the client registers with SARS as a foreign principal, appoints a South African registered agent, and is named as importer of record on the SAD 500 under its own registration. Second, the client does not take its own South African importer registration and TFTIOR provides a locally registered importer of record that is named on the SAD 500. In both structures a licensed customs clearing agent lodges the declaration.

Under the foreign-principal structure the client carries the customs debt to SARS directly and its South African registered agent is liable alongside it; under the local importer-of-record structure the client contracts with TFTIOR and holds no South African registration. Neither structure transfers the client product-disclosure duty, and neither gives the overseas seller a right to recover South African import VAT.

Customs clearance and documents

Who files the customs declaration

Declarations are filed by the importer of record self-clearing, or more commonly a licensed customs clearing agent acting for the importer of record in the SARS Customs system on eFiling, with the SAD 500 customs clearance declaration lodged by EDI with SARS (South African Revenue Service).

  1. The importer of record is registered with SARS and holds a customs client number; VAT vendor registration is a separate step that applies only where the structure makes taxable supplies in South Africa and is not part of obtaining the customs client number. Where a foreign principal is used, a South African registered agent is nominated on form DA 185 and its registered-agent annexure.
  2. Any ITAC import permit for used goods, an NRCS Letter of Authority for an in-scope electrical SKU, and ICASA type approval for a radio SKU are obtained before the goods are shipped.
  3. The clearing agent lodges the SAD 500 against the importer of record customs client number, with the commercial invoice, transport document, packing list, and a DA 59 declaration of origin where a preferential rate is claimed.
  4. SARS assesses the customs duty and 15% VAT, may call for a DA 55 valuation questionnaire, and authorises release once the duty and VAT are paid or deferred.

Inspection channels: SARS risk-engine routing to release, a documentary stop, or a physical examination; goods may be detained in a State warehouse

Required import documents

  • Commercial invoice with unit values and Incoterm
  • Transport document (bill of lading or air waybill)
  • Packing list with serial numbers
  • SAD 500 customs clearance declaration
  • DA 59 declaration of origin where a preferential or lower rate of duty is claimed
  • ICASA type-approval certificate per radio SKU, an NRCS Letter of Authority per in-scope electrical SKU, and an ITAC import permit per used or second-hand SKU

Common rejection triggers:

  • Declared value SARS cannot reconcile to the transaction, referred to Customs valuation on a DA 55
  • Missing serial numbers on high-value compute
  • Product description that does not support the declared tariff heading or the origin claim
  • A controlled SKU presented without its ICASA, NRCS or ITAC document

Customs valuation

SARS applies the six methods of the WTO Valuation Agreement in strict order under sections 65 to 74A of the Customs and Excise Act; Method 1, the transaction value, the price actually paid or payable on an FOB basis, covers most imports. For VAT the added tax value is the customs value, plus 10% for goods from outside the Southern African Customs Union, plus any non-rebated duty.

Related-party pricing must be shown, to the satisfaction of SARS, not to have been influenced by the relationship; SARS can issue a DA 55 valuation questionnaire.

Free-of-charge, warranty-replacement and used units, where there is no sale for export, are valued by a secondary method and SARS can substitute its own value.

How this equipment is classified and its duty

FamilyHS headingDuty positionNote
Servers, compute and storage8471Free of ordinary customs duty under the Southern African Customs Union Common External Tariff (Schedule No. 1 Part 1); South Africa is not a party to the WTO Information Technology AgreementClassification and serial numbers confirmed by SARS on examination.
Networking and transmission equipment8517.62Generally free of ordinary customs duty; the position is classification-dependent for combined or consumer devicesA model with a cellular or Wi-Fi radio needs ICASA type approval.
GPU and AI accelerators, and parts8473.30 and 8471Free of ordinary customs duty; high-value units draw SARS valuation scrutinyOrigin export-control classification is assessed separately.

Duties, taxes and recoverability

Duties, taxes and recoverability

TaxRateBaseOrderRecovery
Ordinary customs duty (Schedule No. 1 Part 1 to the Customs and Excise Act)free on data-processing and networking equipment of headings 8471 and 8517; 0% to 30% on other goods, with ad valorem excise on some audio-visual itemsthe customs value, the FOB transaction value1Non-recoverable / landed cost
VAT on importation (Value-Added Tax Act 89 of 1991)15%the added tax value: the customs value, plus 10% where the goods originate outside the Southern African Customs Union, plus any non-rebated customs duty2Conditional for a registered South African VAT vendor that is the importer named on the bill of entry and imports the goods to make taxable supplies, where the client holds title to the goods and makes the onward taxable supply in South Africa

Import tax recoverability

VAT on importation (Value-Added Tax Act 89 of 1991): Conditional, for a registered South African VAT vendor that is the importer named on the bill of entry and imports the goods to make taxable supplies. Where the importer of record is not a VAT vendor making the onward taxable supply, or the client is not the importer named on the bill of entry, the import VAT is a landed cost; a clearing agent may hold the bill of entry but cannot claim the input tax.

Ordinary customs duty (Schedule No. 1 Part 1 to the Customs and Excise Act): Non-recoverable / landed cost. Customs duty is never recoverable and is always a landed cost, whoever is named as importer of record.

Regulatory approvals

Regulatory approvals

ApprovalAuthorityTriggerBefore shipmentLead time
Type approval of radio and telecommunication equipment (ICASA type approval)Independent Communications Authority of South Africa (ICASA)any SKU that contains a radio transmitter, including an embedded management or wireless moduleYesabout 20 to 40 working days once accredited-lab test reports are complete; an existing model approval in the ICASA type-approval database can be relied on
Letter of Authority under a compulsory specification (NRCS Letter of Authority)National Regulator for Compulsory Specifications (NRCS)a mains-powered SKU, or a power-supply component, that is within the scope of VC 8055Yesaccredited-lab testing plus NRCS evaluation, typically 6 to 12 weeks; the Letter of Authority is valid for 3 years
Import permit for used, second-hand and controlled goods (ITAC import permit)International Trade Administration Commission (ITAC)any SKU that is used, second-hand, refurbished or remanufactured, or otherwise import-controlledYesabout 3 to 15 working days; the permit must be held before the date of shipment and is valid for the calendar year of issue

Wireless and RF equipment

ICASA type approval applies to any SKU that contains a radio, including cellular, Wi-Fi and Bluetooth. Unlike some markets, a server or switch whose only radios are Wi-Fi or Bluetooth is still in scope and needs type approval. An existing model approval in the ICASA type-approval database can be relied on; where a SKU is genuinely radio-free that should be stated on the packing list so SARS does not query it.

An embedded cellular or wireless module brings that SKU into scope even where its primary function is not wireless. SARS will not release non-approved radio equipment. The certificate is issued to a South African registered entity under the Electronic Communications Act 36 of 2005.

An undeclared wireless radio without an ICASA type-approval certificate holds the whole shipment, not just the wireless SKUs.

Product conformity and labelling

Marks:

  • NRCS Letter of Authority under VC 8055
  • ICASA type-approval number and label

Labelling:

  • Importer of record name and SARS customs client number on the import documentation
  • ICASA approval number on each radio SKU

Where a SKU or its power supply is within the scope of VC 8055, its NRCS Letter of Authority must be issued before import. Where a SKU has a radio, ICASA type approval must be in place. Neither is generalised from a component to a whole server, switch or rack; each is assessed per SKU.

Used and refurbished equipment

Used and refurbished: Licence required. South Africa treats all used, second-hand, refurbished and remanufactured goods as controlled imports: an ITAC import permit must be approved before the goods are shipped, under the International Trade Administration Act 71 of 2002. Used electronic equipment is specifically controlled to help prevent the dumping of electronic waste.

SARS may examine the goods to confirm their condition and customs value, and ITAC may require refurbishment evidence.

ITAC import permit (form IE 461 for commercial imports), held before the date of shipment, issued for the stated class of goods and country of origin, valid for the calendar year and non-transferable.

Serial-level refurbishment and reconditioning evidence supports the permit application and the declared customs value.

SARS values used units by a secondary method where transaction value is not accepted.

IT hardware on import

IT hardware import policy

South Africa does not license imports of new commercial IT hardware. The controls that can apply are the Southern African Customs Union tariff position, an NRCS Letter of Authority for any SKU or power supply within the scope of VC 8055, ICASA type approval for any SKU with a radio, and an ITAC import permit for any used or refurbished SKU.

Servers and compute

Servers enter South Africa free of ordinary customs duty, with 15% VAT on the added tax value. SARS reconciles serial numbers on examination and refers high-value compute to Customs valuation on a DA 55. An NRCS Letter of Authority is not triggered by a complete server as such; it attaches to an in-scope internal power supply, or a finished apparatus within the scope of VC 8055, assessed per SKU.

Common hold reasons:

  • SARS valuation stop and DA 55 questionnaire on flagship compute
  • Serial numbers on the packing list not matching the physical cartons

Classification notes:

  • Disaggregated server components may be classified separately by SARS

Networking equipment

Networking equipment is largely free of ordinary customs duty in South Africa. A model with a cellular or Wi-Fi radio needs ICASA type approval. A model with a mains power supply within the scope of VC 8055 needs an NRCS Letter of Authority. A radio-free, externally powered switch needs neither, but that should be stated for SARS.

Common hold reasons:

  • Undeclared embedded wireless capability without an ICASA type-approval certificate

Storage

Storage arrays follow the South African server treatment; there is no additional South African restriction on data-bearing media at import, and encryption features are not separately import-licensed.

Common hold reasons:

  • Serial mismatch on drive-level declarations to SARS

GPU, AI accelerators and export controls

GPU and AI accelerators

South Africa does not require an import licence for GPUs or AI accelerators. On import SARS screens the declared value and classification of high-value units and can issue a DA 55 valuation questionnaire, so a flagship accelerator needs a customs value that will stand up in a SARS valuation review.

Origin-side export controls can apply independently of destination-country import approval, and are assessed against the specific product, origin, end use and end user. The outcome depends on the ECCN and origin classification of the specific accelerator and on its named end user and end use. Where a SKU is above the origin-side performance threshold, or is destined for a large AI training cluster, an origin export licence or an additional end-use review can apply before it ships.

Before booking, TFTIOR confirms the origin export classification of each accelerator SKU, whether an origin export licence is needed and, if so, that it is granted, the named end user and end use screened against origin-side restricted-party lists, and a customs value that will stand up in a SARS DA 55 review.

Dual-use and export controls

Origin-jurisdiction export licensing, for example the United States Export Administration Regulations administered by the Bureau of Industry and Security, is assessed separately from South African import clearance.

Data-center deployment

Compute racks

Cleared as servers in South Africa, free of ordinary customs duty with 15% VAT; SARS reconciles serials and may open a DA 55 valuation query.

Hold pattern: Rack-level serial lists that do not match node serials

Power distribution and UPS

A PDU or UPS is checked against VC 8055 per SKU; where that unit or its power supply falls within scope, an NRCS Letter of Authority is demonstrated before import.

Hold pattern: Missing NRCS Letter of Authority at clearance for an in-scope unit

Switching with wireless management

A switch with a management or wireless radio needs ICASA type approval; a radio-free switch does not.

Hold pattern: Undeclared radio without an ICASA certificate

Structured cabling and optics

Admissible in South Africa, free of ordinary customs duty, with no additional approval.

Recognised data-center regions: Johannesburg, Cape Town.

Operational scenarios

RMA and warranty replacement

Inbound replacementA unit sent abroad for repair and then returned re-enters under Schedule No. 4 rebate item 409.04: the goods must go back to the original exporter with no change of ownership, their essential characteristics unchanged, repaired and not otherwise altered, and a warranty agreement must be available to SARS on request. A warranty replacement that is a different physical unit does not meet the same-goods identification test for 409.04 and is entered on its own merits, with the customs value set on the replacement, unless another Schedule No. 4 rebate item is shown to apply.
Faulty unit outboundThe defective unit is exported under customs supervision, or its destruction is authorised by SARS, against the original entry.
Repair and returnRepair abroad and return runs under rebate item 409.04; VAT is payable on the repair cost.
Duty reliefRelief from ordinary customs duty under Schedule No. 4 rebate item 409.04 for a repair-return; a straight replacement unit is dutiable unless another rebate item is shown to apply.

Importer continuity: Rebate item 409.04 requires the goods to be returned to the original exporter with no change of ownership, so where that relief is relied on the same importer of record is used so identity against the original entry can be shown. It is not established that a different importer is legally barred, and a replacement entered on its own merits carries no such constraint.

Free-of-charge and demo units

A zero-value invoice does not make a shipment duty-free. SARS assigns a customs value to free-of-charge and demo goods and the customs duty and 15% VAT are due on it.

Demo and evaluation units are treated like any other import: ICASA type approval where a SKU has a radio, an NRCS Letter of Authority where a SKU or its power supply is within the scope of VC 8055, and an ITAC import permit if the unit is used. Temporary admission under Schedule No. 4 rebate item 480.00 or an ATA carnet is available where the goods will be re-exported.

Temporary import regimes

RegimeDurationSecurityDischarge
ATA carnet, issued and guaranteed in South Africa by the South African Chamber of Commerce and Industrythe carnet period, generally up to 6 months and within its 1-year validitythe carnet guaranteere-export within the period; the goods may not be sold
Temporary admission under Schedule No. 4 rebate item 480.00up to 6 months, extendable at the discretion of SARSa provisional payment or bond covering the duty and VAT at riskre-export in the same state, or diversion to home use on payment of the duty and VAT

Recovering a stuck shipment

When the consignee cannot import

Where a South African consignee cannot be the importer of record, the importer of record TFTIOR provides can be substituted before arrival, subject to the pre-shipment checks below.

Recovering a stuck shipment

Often fixable:

  • A declaration filed against an invalid or unregistered importer, if caught before release
  • A missing DA 59 declaration of origin where a preference is later substantiated
  • A regulated SKU that arrived without its ICASA type approval or NRCS Letter of Authority: SARS holds the goods and storage and delay accrue, but the position can be regularised once the approval is obtained, or the affected SKUs re-exported

Not fixable after arrival:

  • A used-goods shipment that arrived without an ITAC import permit, which has to be issued before the date of shipment
  • A shipment where a party is sanctioned or the goods are prohibited

What TFTIOR checks before shipment

Before booking freight, TFTIOR verifies:

  • SKU list with manufacturer and full description
  • HS heading per SKU and its Southern African Customs Union tariff position
  • Declared customs value and its basis for a possible SARS DA 55
  • ICASA type-approval status per SKU that contains a radio
  • NRCS Letter of Authority status per electrical SKU or power-supply component within the scope of VC 8055
  • ITAC import permit status for any used, refurbished or remanufactured SKU
  • Serial numbers reconciled to the packing list
  • Named end user, end use and origin export-control classification for AI accelerators

Go / no-go: Freight is booked only when every checklist item is answered and no refusal criterion is met.

TFTIOR will not take on an importer-of-record engagement where:

  • the end user or end use cannot be verified
  • a required ICASA type approval, NRCS Letter of Authority or ITAC import permit does not exist and cannot be obtained before arrival
  • the declared value is not defensible in a SARS Customs valuation review
  • the goods are prohibited or the parties are sanctioned
  • the client asks for a classification or value TFTIOR cannot stand behind in a SARS audit

Clearance timeline, holds and staging

Typical clearance timeline

1
Registration and approvals (pre-shipment)
The importer of record SARS customs client number is active and any ICASA, NRCS and ITAC approvals are in hand.
2
Declaration and routing (same day to 2 days)
The SAD 500 is lodged with SARS and routed to release, a documentary stop, or a physical examination.
3
Assessment and release (1 to 3 days on a clean routing)
The customs duty and 15% VAT are paid or deferred and SARS authorises release.

What causes holds here

CauseHow it happensPreventionImpactRecovery
Undeclared wireless capability without an ICASA type-approval certificateA switch or server with an embedded radio is declared without an ICASA type-approval certificate and SARS stops the shipment.Confirm ICASA type approval at SKU level, or rely on an existing model approval in the ICASA database, before booking freight.1 to 6 weeks plus storageObtain the ICASA certificate or re-export the affected SKUs
SARS valuation stop and DA 55 questionnaireSARS doubts the declared value of high-value compute and requires a DA 55 and often a provisional payment to release the goods.File a defensible customs value with a transfer-pricing or comparable-goods basis in advance.1 to 3 weeksSubmit the valuation file and lodge a provisional payment if required
Missing NRCS Letter of Authority for an in-scope electrical SKUA mains-powered SKU or power supply within the scope of VC 8055 is presented without a Letter of Authority and cannot be released.Secure the NRCS Letter of Authority on an accredited-lab test report before shipment.6 to 12 weeksObtain the Letter of Authority or re-export the SKU
Used goods arriving without an approved ITAC import permitA refurbished or remanufactured unit reaches the port before the ITAC import permit is approved.Approve the ITAC import permit before the goods ship.held until permitted or re-exportedComplete the permit or re-export the shipment

Warehousing and staging

Bonded warehousing in a SARS licensed customs and excise storage warehouse, and staging in a special economic zone, can be arranged in South Africa to consolidate a shipment before a data-center delivery window.

Goods can be held in bond and cleared in tranches against the deployment schedule.

Last-mile delivery

Final-mile delivery into the Johannesburg data-center cluster can be arranged with vetted transport providers and a chain-of-custody handover.

After customs clearance

On import, title is held by the South African importer of record provided by TFTIOR, as named on the SAD 500 customs declaration. It passes to the client when delivery is accepted in South Africa, recorded on the domestic delivery note.

The onward sale of the goods inside the country is a domestic supply subject to 15% VAT. How it is invoiced, and where the import tax falls, depends on how the client structures the transaction. A client with a South African entity usually invoices the domestic sale itself; a client without one commonly arranges the sale DAP with the overseas seller as supplier. Neither is a fixed part of the service, and the structure is agreed for each engagement.

In every structure, import VAT is recoverable only by a party that is a registered South African VAT vendor and is the importer named on the bill of entry.

Records are kept for five years. The importer of record retains the SAD 500, the customs value documentation and the approval certificates, and TFTIOR coordinates the response to SARS audit queries on the entry. Under the Customs and Excise Act 91 of 1964, SARS may reopen an entry and assess underpaid duty or VAT, subject to the applicable statutory limitation rules.

Extended-producer-responsibility obligations sit with the producer or its registered producer responsibility organisation under the extended producer responsibility regulations for electrical and electronic equipment, not the importer of record.

Client document pack:

  • SAD 500 customs clearance declaration and release notification
  • Customs duty and VAT payment or deferment evidence
  • Customs value documentation and any DA 55
  • ICASA, NRCS and ITAC certificates on file

Working with TFTIOR

What the buyer is responsible for

You provide:

  • Product list with models, values and condition
  • Named end user and delivery address in South Africa
  • Target ship date and Incoterm
  • Origin and manufacturer for each SKU

You must not:

  • Understate the customs value to reduce the customs duty or VAT
  • Ship a wireless product before the ICASA type approval is confirmed

You cannot outsource:

  • Accuracy of the product data and specifications
  • Truthfulness of the end-user and end-use statement

What a quote needs

To prepare a quote, send:

  • SKU list with quantities and unit values
  • Condition: new, used, refurbished or remanufactured
  • Cellular, Wi-Fi and encryption features per SKU
  • Named end user and end use
  • Origin and Incoterm
  • Target ship date and destination in South Africa

We respond within two business days with the compliance path and what must be in place before booking.

Frequently asked questions

Can a foreign company be the importer of record in South Africa?

Yes. A foreign company may register with SARS as a foreign principal and act as the importer of record itself, provided it nominates a South African registered agent that accepts liability for its customs obligations; alternatively it may use TFTIOR's locally registered importer-of-record structure. A licensed customs clearing agent lodges the SAD 500 in either case.

Is South African import VAT recoverable when an importer of record is used?

Only where the recovering party is a registered South African VAT vendor and is the importer named on the bill of entry, importing the goods for taxable supplies. Otherwise the 15% import VAT is a landed cost, and a clearing agent cannot claim it.

Can used or refurbished servers be imported into South Africa?

Yes, but they are controlled: an ITAC import permit must be approved before the goods are shipped, under the International Trade Administration Act, and used electronics are watched to prevent e-waste dumping.

Does a warranty replacement have to be imported by the same company?

Not necessarily. Schedule No. 4 rebate item 409.04 concerns the same unit returned after repair, with no change of ownership; a different physical warranty replacement does not satisfy that same-goods test and is entered on its own merits unless another rebate item applies. A different importer is not established as legally barred.

How long does a clean air shipment take to clear in South Africa?

One to three business days once the SAD 500 is lodged and SARS routes it for release; a documentary stop or a physical examination adds several days.

Are there import controls on AI accelerators shipped to South Africa?

South Africa does not require an import licence, but origin-side export licensing such as the US EAR is assessed against the specific accelerator, and SARS scrutinises the declared value of high-value units.

Proof, sources and review

Execution experience

Relevant execution example

Global server lifecycle IOR programme

  • multi-year server lifecycle programme
  • serial-level reconciliation maintained

This is related regional and product experience, not a documented South Africa engagement.

Sources

Review and freshness

Last reviewed 2026-08-30. Next review due 2026-11-28 (90-day cadence).

Request a compliance assessment for South Africa

Send the product list, values, condition, end user and target ship date. We respond with the compliance path and what must be in place before booking.

We respond within two business days with the compliance path and what must be in place before booking.