30 June: TCSPs File or Face Sanctions
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You helped a client register their family trust last year. You filed a CIPC company registration for another. That makes you a Trust and Company Service Provider under Item 2 of FICA Schedule 1. And the FIC just opened the 2026 RCR submission window.
You have seven weeks. Then it gets expensive.
What just happened
On 5 May 2026, the FIC opened the online platform for the 2026 Risk and Compliance Return (RCR). Directive 11 of 2026, published on 31 March, makes electronic submission mandatory for the listed accountable institutions, including TCSPs.
If your practice is registered under Item 2, and many accounting firms are without fully realising it, the deadline is Tuesday, 30 June 2026 at 17:00.
The reporting period covers three years, from 1 April 2023 to 31 March 2026, both dates inclusive.
Why this RCR is different
This one is not a tick-box exercise. The new RCR asks how your practice actually manages the risks of money laundering, terrorist financing, and proliferation financing. It tests whether your Risk Management and Compliance Programme is working in practice, not just sitting in a folder.
As Accounting Weekly covered in Draft Directive 11: From RMCP Documents to Real Accountability, the FIC now expects practitioners to show evidence of ultimate beneficial ownership checks, source-of-funds reasoning, and a clear understanding of how clients use trusts and companies.
If your answer is "we'll figure it out when audited", you are already behind.
The cost of missing 30 June
The FIC has issued more than 286 administrative sanctions in recent rounds, with fines ranging from R10,000 to R50,000 per offence. One estate agency was hit with R266,000 for combined RMCP and RCR failures (read the case here).
Beyond the rand value, a finding of non-compliance damages your standing as an accountable institution. It also weakens South Africa's effort to exit the FATF grey list, which means more scrutiny on every practice, not less.
What to do this week
Confirm whether you are Item 2 registered. If you register companies for clients with CIPC, register or administer trusts with the Master, or arrange nominee structures, you almost certainly qualify. CIBA's recent guide, Are You FIC-Registered? What Every Accountant Must Know Now, walks you through the test.
Download Draft Public Compliance Communication 125 from the FIC website. It explains how to complete the new RCR step by step.
Pull your client files. You will need to show beneficial ownership records, sanctions screening, source-of-funds reasoning, and transaction monitoring for the TCSP clients you served in the reporting window. Use CIBA’s RMCP templates available under your member profile.
Check your goAML message board daily. The FIC posts critical updates and case alerts there.
Submit before 17:00 on 30 June at https://rcr.fic.gov.za.
The bigger play
Many accounting practices registered as TCSPs back in 2023 and then went quiet. The 2026 RCR will surface every gap, missing client due diligence records, outdated RMCPs, weak beneficial ownership checks. Fix it now, not after the FIC writes to you.
You are already doing the work for these clients. Do the file work that protects your practice, and turn FIC compliance into a billable service line.
Watch CIBA’s programmes for more updates on templates and guide that are coming soon!
