FIC: Draft Directive 11 – Submission of risk and compliance returns

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FIC: Draft Directive 11 – Submission of risk and compliance returns

• 23 March 2026
• Miscellaneous
• South African Accounting Academy

Summary:

The Financial Intelligence Centre (FIC) has issued for consultation and comment draft Directive 11 on the submission of risk and compliance returns (RCRs) by certain specified accountable institutions as designated by item in Schedule 1 of the Financial Intelligence Centre Act, 2001 (Act 38 of 2001) (FICA).

 

Article:

The FIC is inviting written comments on draft Directive 11 from affected accountable institutions. Draft Directive 11 applies to the accountable institutions listed as items 1, 2, 3, 9, 11 (excluding bank, mutual bank and co-operative bank credit providers), 14, 20, 21 and 22 of Schedule 1 to the FICA. These affected entities will be required to report the information as required in by end April 2026, and end May 2026, in terms of the schedule provided in the directive (and the web notice).

Draft Directive 11 provides for the manner and format of submission of the 2026 RCR, as well as setting out the information period covered by the RCR and applicable due dates for the submission of the RCRs. The risk and compliance return is an automated return. Specified accountable institutions are required to populate the information directly via the link on the risk and compliance return platform as made available by the Centre. 

An accountable institution that fails to comply with the provisions of this Directive is non-compliant and is subject to an administrative sanction in accordance with section 62E of the Act. 

Comments on draft Directive 11 must reach the FIC by no later than close of business on Wednesday, 25 March 2026. 

Written comments must be submitted electronically via this link only at https://forms.office.com/Pages/ResponsePage.aspx?id=szVSHGOkAUqWp9wmNLKqdFeqGu3LQAtHhSNWTYCyu29UMjgwVEI5UlVBUDhDTE1MNEc3WDE5WTlYVC4u 

Access the relevant FIC 2-page Web Notice at https://www.fic.gov.za/wp-content/uploads/2026/03/Web-notice-Draft-Directive-11-on-submission-of-risk-and-compliance-returns.pdf 

Click here to download the 3-page Draft Directive:

https://www.fic.gov.za/wp-content/uploads/2026/03/Web-notice-Draft-Directive-11-on-submission-of-risk-and-compliance-returns.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, 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, or face administrative sanctions.

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