On 31 March 2026, the Financial Intelligence Centre (FIC) officially issued Directive 11 of 2026, mandating specified accountable institutions to submit their 2026 Risk and Compliance Return (RCR) electronically within set deadlines. Directive 11 came into effect on 1 April 2026. It is no longer in draft form. The obligation to submit your RCR as per Directive 11 is now legally binding.
What is Directive 11?
Similar to Directives 6 and 7, the FIC requires certain accountable institutions to complete and submit a Risk and Compliance Return (RCR) questionnaire electronically to the FIC within set deadlines.
The 2026 RCR is a self-assessment questionnaire, covering three reporting years, on the institution's understanding of the money laundering, terrorist financing and proliferation financing (ML, TF and PF) risks they face and the implementation of risk-based control measures.
The information provided in the RCRs assists the FIC's understanding of institutions and their levels of risk exposure, so that appropriate risk-based supervision may be applied. Using the data from RCRs, the FIC can supervise, monitor and enforce compliance with the anti-money laundering and combating financing of terrorism obligations.
The FIC first introduced the RCR mechanism in May 2023 in support of its risk-based supervision framework and to assist South Africa's work toward exiting the FATF grey list. According to the FIC, the information received through the 2023 RCRs played a critical role in South Africa demonstrating it was remediating the grey listing action items, which contributed to the country exiting the grey listing process.
Failure to submit the RCR by the deadline may result in an administrative sanction under section 62E of the FIC Act. We have seen fines issued to accountable institutions that failed to submit their Directive 6 and 7 returns, and we expect it to be no different with Directive 11.
Which Business are Impacted?
The requirement to submit the 2026 RCR applies to all accountable institutions referred to in items 1, 2, 3, 9, 11 (excluding banks, mutual banks and co-operative bank credit providers), 14, 20, 21, and 22 of Schedule 1 of the FIC Act.
Specified accountable institutions are required to submit questionnaires using information relating to their operations for a designated period between 2023 and 2026.
When is the Deadline?
⚠️ Important update: The deadlines have changed significantly from the draft Directive 11. The draft Directive had proposed deadlines of 30 April and 30 May 2026. The finalised Directive has extended these to 30 June and 31 July 2026 respectively, and submissions cannot be made before 4 May 2026.
Draft PCC 125 of 2026 has been published to provide practical guidance to specified accountable institutions on how to submit the 2026 RCR.
Accountable institutions required to submit between 4 May and 30 June 2026:
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Trust and company service providers (item 2)
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Casinos (item 9)
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Credit providers (item 11, excluding banks, mutual banks, and co-operative banks)
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The Postbank (item 14)
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The South African Mint (item 21)
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Crypto asset service providers (item 22)
Accountable institutions required to submit between 4 May and 31 July 2026:
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Legal practitioners (item 1)
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Estate agents (item 3 )
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High-value goods dealers (item 20) — including dealers in precious metals, precious stones and Krugerrands
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Non-casino gambling institutions (item 9)
Where do You Source the Information?
Accountable institutions should source the information required to complete the 2026 RCR questionnaire from their risk management and compliance programme (RMCP), Companies and Intellectual Property Commission (CIPC) documents, financials, records of regulatory reports filed to the FIC, and other relevant operational records.
What Should You do Now?
Specified accountable institutions are required to submit the RCR electronically via the FIC's online platform (manual submissions are not accepted). To submit, your institution must be registered on the FIC's goAML platform and have a valid FIC organisation identity number (Org ID).
We strongly recommend that you:
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Confirm your registration on the FIC's goAML platform and ensure you have an active Org ID.
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Review Draft PCC 125 for practical guidance on how to complete your submission.
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Review the sample questionnaire (available in the FIC's web notice) and start gathering the required information from your RMCP, CIPC documents, financial records, and FIC reporting history covering the three-year reporting period (2023–2026).
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Submit your RCR within the applicable window (opening 4 May 2026) to avoid administrative sanctions.
Useful links:
Access the FIC's web notice and Directive 11 >>
Download the 2026 RCR Questionnaire here >>
nCino KYC will continue to keep you updated on any further developments. If you need assistance with your FICA compliance, contact us or request a demo to see how we can help you stay on top of your obligations.
