The Financial Intelligence Centre (FIC) has published Draft Public Compliance Communication (PCC) 5E for public comment, setting out updated guidance on registration with the Centre in terms of section 43B of the Financial Intelligence Centre Act (FICA), read together with Draft Directive 10 of 2025.
Draft PCC 5E replaces PCC 5D, issued in October 2023, and incorporates guidance related to Draft Directive 10, which introduces additional requirements for accountable institutions to provide geographic information as part of their registration. Draft Directive 10 was gazetted on 19 December 2025.
Geographic information requirements
In terms of Draft PCC 5E, accountable institutions must provide information on the geographic locations of their head offices, branches, and subsidiaries, including those operating outside South Africa.
This information must be submitted on the FIC’s registration and reporting platform at the time of registration and maintained as part of ongoing updates to an institution’s profile.
Accountable institutions already registered with the FIC will be required to update their registration details within 90 days of the publication of Directive 10.
The draft clarifies that the inclusion of branch and subsidiary information does not in itself require those entities to register as separate accountable institutions, unless they independently meet the definition in FICA.
Proposed methods for submitting geographic information
Draft PCC 5E sets out three proposed methods for submitting the required geographic information and explicitly invites stakeholder comment on these approaches:
- Individual submission of information for each branch or subsidiary.
- Bulk submission of all branch and subsidiary information via an Excel spreadsheet attached to the head-office profile.
- Addition of delegated entities to an existing profile on the system.
These proposed methods relate to how institutions may operationalise the Directive 10 requirements on the FIC’s platform.
Treatment of branches, subsidiaries, and system identifiers
The draft provides additional operational detail on how branches and subsidiaries must be recorded on the FIC’s system. Accountable institutions are required to capture each branch and subsidiary distinctly and associate them with the main accountable institution profile.
The PCC and accompanying Consultation Note indicate that these structures will be reflected through system-generated identifiers, including organisation identity (Org ID) numbers, and linked to the institution’s registration profile on the reporting platform.
Existing registration framework retained
Draft PCC 5E reiterates the existing registration framework set out in PCC 5D, including that:
- Registration with the FIC is mandatory for all accountable institutions listed in Schedule 1 to FICA.
- Registration must be completed in the prescribed manner and must include required information.
- Institutions must maintain and update their registration details.
Failure to register or to update information may result in administrative sanctions.
The draft also confirms that registration is linked to the specific business activities conducted by an institution. Where an organisation operates across multiple Schedule 1 categories, separate registrations per activity may be required.
Delegation structures and group arrangements
The draft expands on the use of delegation structures to link entities within a group and centralise registration and reporting.
Although PCC 5D provided for delegation in limited circumstances, Draft PCC 5E sets out four instances in which delegation may be applied:
- Where an entity has multiple branches that are accountable institutions.
- Where a group contains multiple accountable institutions across different Schedule 1 items.
- Where branches or subsidiaries are not separate accountable institutions but must be recorded on the system.
- Where a special purpose vehicle is linked to a primary accountable institution.
Delegation structures must be formally submitted to and approved by the FIC and enable a compliance officer at head office level to manage registration and reporting across linked entities.
Alignment between registration and reporting
As in PCC 5D, the draft confirms that reporting to the FIC follows the registration structure. Institutions must ensure that their products and services are mapped to the correct registered entity or Schedule 1 activity for reporting purposes.
Roles and responsibilities
Draft PCC 5E maintains the existing framework for roles within the registration system, including:
- The compliance officer, responsible for registering the institution and ensuring that information is accurate and up to date.
- The money laundering reporting officer (MLRO), who may be assigned reporting responsibilities with defined system permissions.
The draft also reiterates requirements relating to system access, including the use of unique user credentials for registered entities and users.
Sector-specific application
Consistent with PCC 5D, the draft includes detailed guidance on how registration requirements apply across different categories of accountable institutions listed in Schedule 1, including legal practitioners, trust and company service providers, estate agents, banks, insurers, collective investment scheme managers, and others.
The PCC explains how registration must be approached in each case, including whether it is required per licence, entity, or activity and how branches and business units are to be treated within each sector.
Comment process
The FIC has invited stakeholders to comment on Draft PCC 5E, after which a final version of the PCC will be issued following consideration of submissions.
Comments must be submitted by the close of business on Friday, 27 March 2026, using the online consultation comments form only.
Click here to download Draft PCC 5E.
