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FIC: Directive 11 re submission of the 2026 RCR
- 09 April 2026
- Miscellaneous
- South African Accounting Academy
Summary:
The Financial Intelligence Centre (FIC) has issued Directive 11 of 2026, mandating specified businesses and professions to submit their 2026 Risk and Compliance Return (2026 RCR) to the FIC electronically within set deadlines.
Article:
Directive 11 provides for the manner and format of submission of the 2026 RCR to the Centre and sets out the RCR information years and periods covered by the 2026 RCR as well as applicable commencement and due dates for the submission of the 2026 RCRs. Directive 11 applies to the specified accountable institutions listed as items 1, 2, 3, 9, 11 (excluding banks, mutual banks, and co-operative bank credit providers), 14, 20, 21 and 22 of Schedule 1 to the FICA.
This Directive takes effect from 1 April 2026 and the 2026 RCR submission date commences on Monday, 4 May 2026.
Trust and company service providers (item 2), casinos (item 9), credit providers (item 11, excluding banks, mutual banks, and co-operative banks), the Post Bank, the South African Mint, crypto asset service providers (item 22) must file their RCRs between 4 May and 30 June 2026.
Legal practitioners (item 1), estate agents (item 3) high-value goods dealers (item 20) – including dealers in precious metals, precious stones and Kruger Rands – and non-casino gambling institutions (item 9) are required to submit their RCRs between 4 May and 31 July 2026.
All accountable institutions are reminded to regularly visit their goAML message board, preferably daily, to check for critical messages from the FIC.
Accountable Institutions are encouraged to use the 38-page 2026 RCR composite questionnaire to gather information before transposing it online, which is available at https://www.fic.gov.za/wp-content/uploads/2026/03/Risk-and-compliance-return-2026-Composite-questionnaire-sample.pdf
Access the Consultation Feedback Note with the comments at https://www.fic.gov.za/wp-content/uploads/2026/03/Consultation-feedback-note-Directive-11-on-the-submission-of-the-2026-risk-and-compliance-return.pdf
Access the Web notice regarding Directive 11 of 2026 at https://www.fic.gov.za/2026/03/31/web-notice-directive-11-rcr/
Click here to download the 8-page Directive 11 of 2026:
https://www.fic.gov.za/wp-content/uploads/2026/03/Directive-11-–-Risk-and-compliance-return.pdf
Relevance to Auditors, Independent Reviewers & Accountants:
- The Financial Intelligence Centre Act (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.
- As an auditor and independent reviewer, you need to consider amendments, regulations and directives that are gazetted relating to FIC and accountable institutions, to ensure that your clients (or even your own practice) comply with their reporting obligations.
- As a TCSP that is regarded as an AI, you need to submit your RCR by the deadline date, or face administrative sanctions.
Relevance to Your clients:
- Relevant entities (specifically accountable institutions) have a duty to comply with the FIC Act, otherwise they could be held liable.
- Relevant entities should be aware of amendments, regulations and directives that are gazetted relating to FIC and accountable institutions, to ensure that they comply with their reporting obligations.
- All accountable institutions need to submit their RCR by the deadline date, or face administrative sanctions.