Important regulatory update: FIC Directive 11 gazetted
Recently, the Financial Intelligence Centre (FIC) finalised Directive 11 of 2026, officially gazetting it on 31 March 2026. The public consultation phase has concluded and this critical directive is now active, outlining the specific timeframes and formatting requirements for your 2026 Risk and Compliance Returns (RCR’s).
While the directive is officially in force as of 1 April 2026, the practical submission guide, Draft Public Compliance Communication 125 (PCC 125) remains open for consultation and comment. Because the final "how-to" mechanics are still being refined, you cannot actually submit your return right now.
Who this applies to
Directive 11 does not apply to every single financial entity, but it strictly targets specified Accountable Institutions designated in Schedule 1 of the FIC Act. If your business or FSP falls into any of the following categories, you must prepare to submit:
Item 1: Legal Practitioners / Attorneys
Item 2: Trust 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: South African Postbank
Item 20: High-Value Goods Dealers
Item 21: South African Mint Company
Item 22: Crypto Asset Service Providers (CASP’s)
Your 2026 RCR timeline
To maintain compliance efficiency and avoid administrative sanctions, mark these critical dates on your 2026 compliance calendar:
Effective date: 1 April 2026 (Directive 11 is officially in force).
Submissions open: 4 May 2026.
Deadline: 30 June 2026 (No later than 17:00)
Item 11, excluding banks: Must report on data from 1 July 2023 to 31 March 2026.
Items 14, 21 and 22: Must report on data from 1 July 2023 to 31 March 2026.
Items 2 and 9: Must report on data from 1 April 2023 to 31 March 2026.
Deadline: 31 July 2026 (No later than 17:00)
Item 20: Must report on data from 1 July 2023 to 31 March 2026.
Items 1, 3 and 9: Must report on data from 1 April 2023 to 31 March 2026.
What this means for you
The FIC expects your return to accurately reflect your AI’s understanding of money laundering, terrorist financing, and proliferation financing risks, along with your current implementation of risk-based controls. Because the submission portal on the GoAML platform is currently closed, you have the advantage of time to prepare and obtain info/documents to help you complete the questionnaire without the pressure of an immediately looming deadline.
Action required (entirely your choice)
No immediate action is required at the moment, due to PCC 125 still being open for comments and consultation. However, to stay sharp and ensure your data is ready when the portal goes live, we would recommend that you execute the following steps:
Download the questionnaire: The FIC has provided a downloadable version of the 2026 RCR questionnaire.
Collect data in the meantime: Use this document strictly as an internal data collection worksheet. You are more than welcome to preview the questions and gather your internal data before submissions open.
Wait for 4 May 2026: Remember, while you can prepare your answers today, you cannot actually file the return yet. All collated data must be held until the official electronic submission period commences on 4 May 2026 on the GoAML platform.
Please reach out to our team if you have any questions, we are here to help.
