Many businesses that extend credit may still be uncertain whether they fall within the Financial Intelligence Centre’s definition of a “credit provider” – particularly where lending is incidental, embedded in commercial arrangements, or structured in non-traditional ways.
Public Compliance Communication 23A (PCC 23A), dated 30 March 2026, was issued to clarify how Item 11 of Schedule 1 should be interpreted. It confirms the broad reach of the definition while addressing key grey areas – but for many firms the practical question remains: are you in or out?
That uncertainty now has immediate consequences. Directive 11 of 2026 introduces mandatory Risk and Compliance Returns (RCRs) for specified accountable institutions. RCR submissions open on 4 May 2026, and Item 11 institutions – credit providers – must submit by 30 June 2026 (no later than 5pm). The RCR requires structured disclosures about money-laundering risk exposure and the effectiveness of compliance controls – making this far more than a routine filing.
To help credit providers prepare, Moonstone Compliance will host a practical webinar on Tuesday, 12 May 2026, focused on the real-world implications of PCC 23A, Directive 11, and the RCR. The session will explain how to interpret the definition of “credit provider” in practice, what Directive 11 requires, and how to complete the RCR with confidence ahead of the deadline.
The webinar runs from 10am to 11.30am on Microsoft Teams. Attendance is free for Moonstone clients, with a fee of R250 for non-clients.
Registrations are now open via the Moonstone website. Please click here. Registration closes on 8 May, and payment must be received by 10 May.
The presenters are:
- Gerrit Viviers, National Credit Act (NCA) specialist at Moonstone Compliance and an admitted attorney with experience in credit risk and forensic investigations.
- Mieke Whitehead, an FSCA-approved compliance officer and admitted attorney advising accountable institutions on their FICA and NCA obligations.
In 90 minutes, they will cover:
- The interpretation of “credit provider” under Item 11 of Schedule 1, in light of PCC 23A.
- The key risk indicators relevant to the sector.
- The requirements of Directive 11 and what must be disclosed.
- A practical, step-by-step walkthrough of completing the RCR.
A Q&A session will allow attendees to raise practical questions ahead of the submission deadline.
There are no CPD points for attending the webinar.
For more information, contact events@moonstonecompliance.co.za or 021 883 8000.
This webinar a must-attend session for credit providers looking to ensure compliance, strengthen their risk framework, and stay ahead of regulatory scrutiny.
