The Financial Intelligence Centre (FIC) has published Draft Directive 11 of 2026 for public consultation, proposing that specified accountable institutions submit risk and compliance returns (RCRs) to the Centre.
The draft directive, released on 11 March 2026, is accompanied by a Consultation Note, which includes links to a draft composite RCR questionnaire and to draft sector-specific questionnaires.
Issued in terms of section 43A of the Financial Intelligence Centre Act (FICA), the directive – if finalised – will require affected institutions to submit the RCR electronically.
The RCR is intended to collect entity-level information about an accountable institution’s understanding of its money laundering, terrorist financing, and proliferation financing (ML/TF/PF) risks, together with the risk-based controls and compliance measures it has implemented.
According to the consultation note, this information will enable the FIC to:
- better understand and assess ML/TF/PF risks at an institutional level,
- conduct informed risk-based supervision and monitoring, and
- apply proportionate supervisory responses.
The initiative also supports South Africa’s compliance with Financial Action Task Force standards, particularly Immediate Outcomes 1, 3, and 4.
Institutions covered
Draft Directive 11 applies to accountable institutions listed in the following items of Schedule 1 to FICA:
- Item 1 – Legal practitioners
- Item 2 – Trust and company service providers
- Item 3 – Estate agents
- Item 9 – Gambling institutions
- Item 11 – Credit providers (excluding banks, mutual banks, and co-operative banks acting as credit providers)
- Item 14 – South African Postbank Limited
- Item 20 – Dealers in high-value goods
- Item 21 – South African Mint Company (limited scope)
- Item 22 – Crypto asset service providers (CASPs)
The directive does not apply to any bank, mutual bank, or co-operative bank that carries on the business of a credit provider under Item 11.
Questionnaires
The consultation materials include a composite RCR questionnaire, together with sector-specific RCR questionnaires. The links are provided below:
Accountable institutions will complete the questionnaires directly on the FIC’s electronic RCR submission platform.
Responses must be provided based on the institution’s own understanding of its ML/TF/PF risks and the risk-based controls it has implemented to comply with FICA.
Reporting periods and submission deadlines
Upon final publication of Directive 11, the affected accountable institutions will be required to submit RCR data to the FIC in terms of the information periods and due dates set out in the table below:
Consultation process
The FIC has invited stakeholders to comment on Draft Directive 11 and the draft RCR questionnaires.
Comments must be submitted by close of business on Wednesday, 25 March 2026, using the online form.
After considering submissions, the Centre may publish a final directive. The obligation to submit the RCR will apply only once the directive has been finalised and published, and the directive will take effect on the date of publication.
Failure to comply with a directive issued under FICA constitutes non-compliance with the Act and may result in administrative sanctions under section 62E.
