Does the revised SBD 4 apply to municipal tenders?

PFMA SCM Instruction 12 of 2026/27 is addressed to national and provincial departments, constitutional institutions and Schedule 2 and 3 public entities. Municipalities and municipal entities work under the MFMA and use the MBD forms, including MBD 4. If a municipal pack includes an SBD 4 instead, complete the form the municipality issued.

My director has a dormant company on the CSD. Do I list it?

The table asks for all companies registered in the CSD with their status (active, inactive or deleted), and the warning under it refers to active companies. Listing every linked company with its status is the safer reading. If you are unsure, ask the buyer in writing before the closing date.

We are a joint venture. Can the partners still talk to each other about the bid?

Partners in a joint venture prepare one bid together. The 2022 SBD 4 said such communication would not be treated as collusion; the revised form no longer says so. Read the bid document's joint venture conditions and, if they are silent, ask the buyer how JV partners should complete SBD 4.

Guide

SBD 4 bidder's disclosure: the 2022 form and the 2026 revision

SBD 4, the bidder's disclosure, is where you declare whether anyone in your business works for the state, has a relationship with the buyer's staff, or has interests in other companies, and where you certify that you did not collude with competitors. National Treasury replaced the form in 2026. The revised version applies from 1 November 2026, and it is stricter.

Applies to: National and provincial departments, constitutional institutions and Schedule 2 and 3 public entities (PFMA). Municipalities use MBD 4.
Last reviewed: 10 October 2026

The issued tender pack always takes precedence. Buyers customise the standard forms and add their own conditions, so complete the forms and follow the rules in the pack you received. This guide explains the official forms; it is general information, not legal advice.

Which SBD 4 applies to your bid

SBD 4 versions
Version	Issued under	Applies
2022 SBD 4	Annexure A to PFMA SCM Instruction 3 of 2021/22	From 1 April 2022 to 31 October 2026
Revised SBD 4	Annexure A to PFMA SCM Instruction 12 of 2026/27	From 1 November 2026

Instruction 12 of 2026/27 was signed on 14 June 2026 with an effective date of 1 August 2026. An amendment signed on 31 July 2026 moved the effective date to 1 November 2026. Neither document says how to treat a tender advertised before 1 November that closes after it. The practical reading is that bids closing up to 31 October 2026 use the 2022 form and bids closing from 1 November 2026 use the revised form, but for a tender that straddles the date, the form in the issued pack is the one to complete.

The issued pack decides

Complete the SBD 4 that is in the tender pack the buyer issued. A tender advertised in October 2026 that closes in November may already include the revised form. If the pack and the dates do not seem to match, ask the buyer's bidding procedure contact in writing before you submit.

Under paragraph 7 of Instruction 3 of 2021/22, which Instruction 12 leaves in place, SBD 4 applies to all procurement, whatever the value or method, except petty cash purchases, and must be completed by everyone who responds. Buyers may build the SBD 4 content into their own bid documents, including requests for quotations, but may not change its content or the order of the information.

What changed in the 2026 revision

Related companies must be listed with their CSD numbers. Question 2.4 (2.3 on the 2022 form) still asks whether the bidder, its directors, trustees, shareholders, members, partners or anyone with a controlling interest has an interest in any other related enterprise. If the answer is yes, the revised form now asks you to list every company registered on the CSD in a table, with its supplier registration number (MAAA) and its status (active, inactive or deleted).
Not disclosing leads to disqualification. The revised form states: "Failure to disclose all CSD-registered active companies linked to all Directors will lead to disqualification."
"Organ of state" replaces "the state". Question 2.1 now asks whether the bidder or any director, trustee, shareholder, member or partner is employed by an organ of state as defined in section 239 of the Constitution. The table column is now "Name of organ of state", and state employee numbers are no longer asked for. Unlike the 2022 form, this question no longer mentions "any person having a controlling interest"; question 2.4 still does.
The joint venture exception is gone. The 2022 form said communication between partners in a joint venture or consortium would not be treated as collusive bidding. The revised declaration 3.3 drops that sentence and the joint venture definition that went with it.
Shorter, firmer wording. The bid will be disqualified if the disclosure "is found to be false" (the 2022 form said "not to be true and complete in every respect"). Suspicious bids may be reported to the Competition Commission and referred to law enforcement agencies (the 2022 form named the National Prosecuting Authority), and a bidder may be restricted from business with the state for up to 10 years. The closing certification no longer refers to paragraph 6 of Instruction 3: you accept that the procuring institution may reject the bid or take appropriate action if the declaration is false.

Walking through the revised form

1. Purpose of the form

Any person may bid. A person listed on the Register for Tender Defaulters or the List of Restricted Suppliers is automatically disqualified.

2. Declarations

2.1 and 2.2 Employment by an organ of state. Yes or no for the bidder and every director, trustee, shareholder, member or partner. If yes, give each person's full name, ID number and the organ of state.
2.3 Relationships with the buyer's staff. Do you, or anyone connected with the bidder, have a relationship with anyone employed by the procuring institution? If so, give particulars.
2.4 Interests in related enterprises. If yes, list every CSD-registered company with its MAAA number and status.

3. General declaration

The person signing certifies that the bid was prepared independently, with no consultation or arrangement with competitors on prices, quantities, market allocation or whether to bid; that the bid terms were not disclosed to competitors; that there were no arrangements with the buyer's officials beyond clarifications; and that the bidder did not help draft the specifications or terms of reference.

Before you sign

Pull a list of every company each director is linked to from CIPC and the CSD, including dormant and deregistered ones, and record each MAAA number and status.
Ask every director, member and shareholder in writing whether they work for any organ of state, including part-time and municipal posts.
A "yes" to employment by an organ of state is not something to hide. Clause 2.7 in Part B of SBD 1 says no bids will be considered from persons in the service of the state, or from companies whose directors are, so resolve it before you bid.
Sign with the name and designation of a person the company resolution authorises.

Questions

Does the revised SBD 4 apply to municipal tenders?: PFMA SCM Instruction 12 of 2026/27 is addressed to national and provincial departments, constitutional institutions and Schedule 2 and 3 public entities. Municipalities and municipal entities work under the MFMA and use the MBD forms, including MBD 4. If a municipal pack includes an SBD 4 instead, complete the form the municipality issued.
My director has a dormant company on the CSD. Do I list it?: The table asks for all companies registered in the CSD with their status (active, inactive or deleted), and the warning under it refers to active companies. Listing every linked company with its status is the safer reading. If you are unsure, ask the buyer in writing before the closing date.
We are a joint venture. Can the partners still talk to each other about the bid?: Partners in a joint venture prepare one bid together. The 2022 SBD 4 said such communication would not be treated as collusion; the revised form no longer says so. Read the bid document's joint venture conditions and, if they are silent, ask the buyer how JV partners should complete SBD 4.

How Lula Bid helps

Picks the SBD 4 version by the tender's closing date: the 2022 form for bids closing before 1 November 2026 and the revised form from then on. Before 1 November you can also choose the revised form if the pack uses it.
Warns before you sign when an answer could disqualify the bid, such as "yes" to employment by an organ of state, or a related-company answer without CSD (MAAA) numbers on the revised form.
On the Prepare package, writes your answers onto the SBD 4 page in the buyer's own pack, or onto the official Treasury Word form.

You still check every answer and sign the forms yourself. See what each package includes

Official sources

PFMA SCM Instruction 12 of 2026/27: Substitution of Standard Bidding Document 4 · National Treasury, Office of the Chief Procurement Officer
Amendment of PFMA SCM Instruction 12 of 2026/27 (effective date moved to 1 November 2026) · National Treasury, Office of the Chief Procurement Officer
Revised SBD 4 Bidder's disclosure (Annexure A to PFMA SCM Instruction 12 of 2026/27, Word) · National Treasury, Office of the Chief Procurement Officer
PFMA SCM Instruction 3 of 2021/22: Enhancing compliance, transparency and accountability in SCM (with the 2022 SBD 4 as Annexure A) · National Treasury, Office of the Chief Procurement Officer
PFMA SCM Instruction Notes (current) · National Treasury, Office of the Chief Procurement Officer

Last reviewed 10 October 2026 against these documents. Forms and instructions change; check the buyer's pack and National Treasury's site for later versions.