FIC: Directive 10 on information pertaining to geographic locations of Accountable Institutions

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FIC: Directive 10 on information pertaining to geographic locations of Accountable Institutions

• 17 August 2026
• Miscellaneous
• South African Accounting Academy

Summary:
The Financial Intelligence Centre (FIC) has issued Directive 10, which specifies that certain accountable institutions listed in Schedule 1 of the Financial Intelligence Centre Act, 2001 (FICA) must submit specific geographic data regarding their head offices, branches, and domestic or foreign subsidiaries, when registering with FIC.

Article:

The effective date of Directive 10 regarding geographic location information is 31 July 2026, which is when it was officially gazetted.

Existing registered Accountable Institutions (AIs) have a 90-day window from 31 July 2026 to update their registration details with the required location data, thus AIs must update or submit location details via the FIC registration system by 29 October 2026.

The Directive, which is issued in accordance with section 43B(2) of the FICA, applies to the following accountable institutions:

• Item 1: Legal practitioners
• Item 2: Certain trust and company service providers
• Item 3: Estate agents
• Item 9: Gambling institutions
• Item 11: Credit providers (excluding banks, mutual banks, and co-operative bank credit providers)
• Item 14: The South African Postbank Limited
• Item 20: High-value goods dealers
• Item 21: The South African Mint Company (RF) (Pty) Ltd
• Item 22: Crypto asset service providers

as listed in Schedule 1 to the FICA, to provide information regarding their head office, branch offices, each subsidiary’s head office, and the branch offices of such subsidiaries, in or outside the Republic of South Africa, to determine the geographic location for group structures.

The FIC published draft Directive 10 on 19 December 2025 inviting written comments from all accountable institutions, supervisory bodies and reporting persons by 13 February 2026. Refer to our previous Alert dated 9 January 2026

The FIC received comments from the banking industry, crypto asset service providers, casinos, attorneys and various other persons, which comments have been considered in the compilation of final Directive 10.

An accountable institution that fails to comply with any provision of this Directive is noncompliant and is subject to an administrative sanction in accordance with section 43B(2) read together with sections 61A and 45C of the FICA. 

Click here to download the 5-page Directive document:

https://www.fic.gov.za/wp-content/uploads/2026/07/Directive-10-On-information-pertaining-to-geographic-locations.pdf 

Relevance to Auditors, Independent Reviewers & Accountants:

• FICA is yet another piece of legislation that your clients must comply with, and which you must assess compliance with.  If they don’t comply with the relevant laws and regulations, you have certain reporting obligations in terms of NOCLAR (NOn-Compliance with Laws And Regulations) – this could include reporting to management, qualifying your audit opinion, reporting a Reportable Irregularity, etc.
• Auditors, Independent Reviewers and Accountants should be aware of the latest publications and guidance issued by regulators, such as the FIC – to enable their assessment of accountable institutions’ compliance with FICA.
• When advising clients or performing this function on their behalf, practitioners should be aware of the finer details and specific guidance on failure to report to FIC.
• As an accountable, you also need to comply with FICA in your workplace.

Relevance to Your clients:

• An entity (company or close corporation) has a duty to comply with the FICA, and accountable institutions should fulfil their reporting obligations, otherwise non-compliance could lead to financial sanctions.
• Relevant Accountable Institutions (companies and CCs) should be aware of the latest publications and guidance issued by regulators, such as the FIC.

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