On the 11 March 2026 The Financial Intelligence Centre (FIC) published Draft Directive 11 of 2026 for public consultation. If (vis. when) it is published, it will affect a considerable number of specified accountable institutions and will require that they submit risk and compliance returns (RCRs) to the Centre.
What is Draft Directive 11 ?
Similar to Directive 6&7, the FIC is requiring certain accountable institutions to complete and submit another Risk and Compliance Return (RCR) questionnaire through the FIC's online platform.
The questionnaire covers how each institution understands its money laundering, terrorist financing, and proliferation financing risks, and what controls they have in place.
According to the consultation note, this information will enable the FIC to:
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better understand and assess ML/TF/PF risks at an institutional level,
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conduct informed risk-based supervision and monitoring, and
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apply proportionate supervisory responses.
Failure to submit by the deadline can result in an administrative sanction under section 62E of the FIC Act. We are seeing fines come through for Accountable Institutions who did not submit their Directive 6&7 returns and we expect it to be no different with Directive 11
Which business are impacted
The following accountable institution types are in scope:
Item 1 – Banks
Item 2 – Mutual banks
Item 3 – The Postbank
Item 9 – Casinos and gambling/gaming institutions (both casino and non-casino)
Item 11 – Credit providers (but NOT banks, mutual banks, or co-operative banks that act as credit providers — these are specifically excluded)
Item 14 – Estate agents
Item 20 – High Value Goods Dealers (HVGDs), including dealers in precious stones, precious metals, and Krugerrands
Item 21 – Legal practitioners (attorneys)
Item 22 – Crypto Asset Service Providers (CASPs)
**Note that HVGD's may also be credit providers and we hope there will be clarity around whether intuitions must submit a combined submission, or one for each schedule item.
When is the deadline?
Please note that these are the deadlines given in the draft and therefore may be subject to change
By 30 April 2026 at 17:00 – Covering Period 1 July ’23 to 31 March ‘26 (both dates inclusive)
Item 11 – Credit providers
Item 14 – Estate agents
Item 21 – Attorneys
Item 22 – CASPs
By 30 April 2026 at 17:00 – Covering Period 1 April ’23 to 31 March ‘26
Item 2 - Trust and Company Service Providers
Item 9 – Casino gambling/gaming operators
By 30 May 2026 at 17:00 – Covering Period 1 April ’23 to 31 March ‘26
Item 1 – Banks
Item 3 – Postbank
Item 9 – Non-casino gambling/gaming operators
By 30 May 2026 at 17h00 – Covering 1 July ‘23 to 31 March 2026
Item 20 - HVGD
What's next?
The FIC had invited stakeholders to comment on Draft Directive 11 and the draft RCR questionnaires. The deadline for comments needed to be submitted by close of business on Wednesday, 25 March 2026. Based on this we expect that a final version will be published soon.
Attached is the DRAFT Directive 11 and the RCR questionnaire. We encourage all relevant accountable institutions have a look at these in preparation.
NCino KYC will keep you updated as soon as a finalised version becomes available.
Questionnaires
The consultation materials include a composite RCR questionnaire, together with sector-specific RCR questionnaires.
The links are provided below:
Download The draft here>>
Download the RCR Questions here>>
