TCSPs Must Urgently File Their Risk Compliance Returns
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The deadline has passed for many. Penalties are coming. And the numbers show that most accounting practices registered as company or trust service providers have not yet done what the FIC requires.
On 17 July 2026, the Financial Intelligence Centre (FIC) issued a media release warning that thousands of specified accountable institutions failed to submit their 2026 Risk and Compliance Returns (RCRs) by the 30 June 2026 closing date. If your practice is registered with the FIC as a company service provider or trust service provider, this applies to you.
What is the RCR?
The RCR is an annual online report that accountable institutions must submit to the FIC. It covers your practice's understanding of money laundering and terrorist financing risks, and what controls you have in place to manage them. The 2026 RCR covers the three-year period from 1 April 2023 to 31 March 2026 and was required under Directive 11, issued on 31 March 2026.
How bad is the non-compliance rate?
The numbers from the FIC's own data are sobering. As at 30 June 2026, only 38.85% of accounting practices registered as company service providers had submitted their RCR. By 15 July 2026, that number had only risen to 51.71%, meaning nearly half of all registered accounting practices in this category still had not filed. Trust service providers registered as accountants showed a slightly better rate, with 68.32% having submitted by 15 July, but more than 30% are still outstanding.
Across all sectors in the first group, only 48.14% of registered institutions had filed by 15 July 2026, two weeks after the deadline.
The FIC has made clear it cannot ignore this. Enforcement action, including financial penalties, will follow for those who have not complied.
What about the second deadline?
If your practice is registered as a company service provider or trust service provider, your deadline was 30 June 2026, and you are already late. The second group, which includes legal practitioners, estate agents, dealers in precious metals and stones, and non-casino gambling institutions, has until close of business on 31 July 2026. Their submission rate as at 15 July 2026 was only 11.82%, which is deeply concerning given how close that deadline is.
What happens if you don't file?
Non-compliant institutions face administrative financial penalties. As covered in our earlier article on FIC warnings to accountants, penalties can range from R10,000 to R50,000 for non-compliance. The FIC has also confirmed it will proceed with sanctions where institutions fail to act.
As explained in our guide on what it means to be an FIC-registered accountant, being registered as an accountable institution creates ongoing legal obligations. Filing the RCR is one of them, and it cannot be ignored.
What you need to do now
If you are registered with the FIC as a company service provider or trust service provider and have not yet submitted your 2026 RCR, do it today. The FIC portal remains open for submissions. File using this link.
If you are not sure whether your practice should register as an accountable institution, or if you need help understanding what the RCR requires, CIBA has practical resources to help. The FIC Compliance for Accountable Institutions Short Course includes guidance and manual templates to help you understand your obligations and complete your submission correctly.
Do not wait. The FIC is not accepting excuses, and neither will the penalty notice.