Certain accountable institutions will have to submit their Risk Management and Compliance Programmes (RMCPs) annually to the Financial Intelligence Centre (FIC), under a draft directive published for comment on 31 July 2026.
The proposal will introduce a new annual compliance obligation for the affected institutions and require updated RMCPs to be submitted within 10 business days of approval.
Draft Directive 12 proposes to require the following accountable institutions listed in Schedule 1 to the Financial Intelligence Centre Act (FICA) to submit their RMCPs annually:
- Item 1: Legal practitioners
- Item 2: Certain trust and company service providers
- Item 3: Estate agents
- Item 9: Gambling institutions
- Item 11: Credit providers (excluding banks, mutual banks, and co-operative bank credit providers)
- Item 14: The South African Postbank Limited
- Item 20: High-value goods dealers
- Item 21: The South African Mint Company (RF) (Pty) Ltd
- Item 22: Crypto asset service providers
The accountable institutions listed in items 1, 2, 3, 9, and 11 (excluding banks, mutual banks, and co-operative bank credit providers) will have to submit a copy of their RMCPs by 30 September each year, starting in September 2026.
The accountable institutions listed in items 14, 20, 21, and 22 will have to submit a copy of their RMCPs by 31 October 2026. However, the draft directive states that the deadline in subsequent years will be 30 October, whereas the accompanying Consultation Note and Web Notice specify 31 October each year. In response to Moonstone’s request to clarify which date is correct, the FIC said the inconsistency will be corrected during the consultation and finalisation process. For purposes of the consultation, the intended annual submission date for accountable institutions listed in items 14, 20, 21, and 22 is 31 October.
The accompanying Consultation Note says the annual submissions will enable the Centre to “holistically monitor” compliance across accountable institutions.
The specified accountable institutions will have to submit their RMCPs using the FIC’s registration and reporting platform.
One of the more significant operational requirements appears in paragraph 8 of the draft directive. If an institution updates and approves its RMCP after making its annual submission, it will have to submit the revised version to the FIC within 10 business days of approval. Institutions therefore cannot treat the exercise as an annual filing only; revisions approved during the year will also have to be submitted.
Newly established accountable institutions will have to submit their RMCPs within 90 days of commencing business, rather than waiting for the next annual submission deadline.
Draft Directive 12 refers to a commencement date of 3 August 2026, even though the Consultation Note and Web Notice state that comments are invited until the close of business on Monday, 21 August 2026.
Responding to Moonstone’s request for clarification, the FIC said the effective date of any final Directive will be confirmed once the consultation process has been concluded and the Directive has been formally issued. The final Directive will apply from a future date and will not be retrospective.
Comments must be submitted on the online consultation form only.
Note: This article was updated at 4.15pm on 3 August 2026 to include the FIC’s responses to Moonstone’s queries.
