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FIC: Draft PCC 125 on 2026 RCRs
- 10 April 2026
- Miscellaneous
- South African Accounting Academy
Summary:
The Financial Intelligence Centre (FIC) has issued for consultation and comment Draft Public Compliance Communication 125 of 2026 (Draft PCC 125) on the format and manner of completion and submission of the 2026 Risk and Compliance Returns (RCRs) as contemplated by Directive 11 of 2026 by specified accountable institutions as designated items in Schedule 1 of the Financial Intelligence Centre Act, 2001 (FICA).
Article:
Draft PCC 125 assists specified accountable institutions (in particular, items 1, 2, 3, 9, 11 (excluding banks, mutual banks, and co-operative bank credit providers), 14, 20, 21 and 22 of Schedule 1 of FICA) through the provided guidance on the format and manner of completion and submission of the 2026 RCRs to the Centre as contemplated by Directive 11 of 2026 by specified accountable institutions as designated items in Schedule 1 of the FIC Act. Refer to our previous Alert dated 9 April 2026 for more info on Directive 11
Draft PCC 125 also guides the specified accountable institutions on how to prepare for the submission of the specified RCR data information for specified years and periods, and to complete the questionnaire in the 2026 RCRs, and then submit the 2026 RCR electronically in a timely manner to the Centre.
The FIC in Draft PCC 125 provides a practical solution on how the specified accountable institutions can have the required 2026 RCR data information readily available by Monday, 4 May 2026, which is the envisaged commencement date for the submission of the 2026 RCR to the Centre, in terms of Directive 11.
Comments on Draft PCC 125 must reach the FIC by no later than close of business on Friday, 24 April 2026. This can be done online at https://forms.office.com/Pages/ResponsePage.aspx?id=szVSHGOkAUqWp9wmNLKqdDhdo1-vzNpPh8emiL5DIJdUMzdIV1MxR0ZBVElPR0lGMEQ1VjQ1VlNXVS4u
Access the Web notice regarding Draft PCC 125 at https://www.fic.gov.za/2026/03/31/call-for-comments-draft-pcc-126-on-2026-risk-and-compliance-returns/
Access the related Consultation Note at https://www.fic.gov.za/wp-content/uploads/2026/03/2026.3-GN-Consultation-Note_Draft-PCC-125_RCR-submission.pdf
Click here to download the 16-page Draft PCC 125:
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.