The deadline for specified accountable institutions to submit their 2026 Risk and Compliance Returns (RCRs) expired on Friday, with the Financial Intelligence Centre (FIC) warning the day before that many returns were still outstanding.
The Centre also said many institutions were submitting the wrong information or leaving registration issues until the last minute, creating a backlog in its ability to assist.
The deadline of the close on business on 31 July 2026 applied to legal practitioners, estate agents, non-casino gambling institutions, motor vehicle dealers, other high-value goods dealers, dealers in precious metals (including Krugerrand dealers), and dealers in precious stones.
The requirement to submit the RCRs was contained in Directive 11, issued on 31 March. Directive 11 also applied to another group of institutions, including crypto asset service providers, company service providers, non-bank credit providers, trust service providers, and casinos. These accountable institutions were given until 30 June to submit their returns.
To submit the RCRs, accountable institutions must have registered with the FIC and ensured that their details on the Centre’s online registration and reporting system are up-to-date, the Centre said in a statement on 30 July.
The FIC said most of the queries it receives concern registration and/or the updating of registration details. “This is causing a backlog in the FIC’s ability to assist the accountable institutions in their submission of the 2026 RCR,” the statement said.
Although the FIC can assist with registration and/or updating registration details, sufficient time needs to be allowed to complete these processes.
The FIC said institutions that need assistance or have queries about the completion of the RCR should log their queries on the FIC’s website. The queries should be marked as “Urgent: 2026 RCR-related”.
The FIC said it has received an increasing number of Risk Management and Compliance Programmes (RMCPs). The Centre is concerned that this is because accountable institutions do not understand the difference between the RCR and an RMCP.
Directive 11 requires the submission of the RCR only, not an RMCP.
The FIC also said some accountable institutions were incorrectly submitting separate RCRs for individual branches.
The FIC emphasised that where a head office submits an RCR on behalf of the accountable institution, the return should constitute a consolidated submission covering the accountable institution as a whole, including all branches forming part of that legal entity.
“Accordingly, the return should reflect the activities, compliance controls, risk exposure, and operational information of the full legal entity, and should not be limited to the activities or information pertaining only to the head office,” the Centre said.
Warnings came before the deadline
The FIC’s 30 July statement said that “a large proportion of accountable institutions have not yet submitted their returns”.
This is despite the Centre issuing a statement on 17 July in which it warned that failing to submit the RCRs by the deadlines rendered institutions non-compliant and therefore subject to enforcement action, which may include financial penalties.
As of 15 July, only 11.82% of the 40 827 institutions required to submit by 31 July had done so. Legal practitioners recorded the lowest compliance rate at 9.7%, followed by Krugerrand dealers (10.8%) and estate agents (11.8%). Motor vehicle dealers had the highest submission rate at 20.3%, ahead of dealers in precious stones (20.1%) and dealers in precious metals (14.2%).
Many institutions that were required to file their returns by 30 June also failed to meet the deadline.
According to the FIC, only 2 038 of the 5 636 institutions required to file by 30 June had done so by the deadline – a submission rate of just 36.1%. Although additional returns were received during the following two weeks, the overall submission rate had increased to only 48.1% by 15 July.
