The RMCP deadline has passed. If you missed it, act now
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The deadline for the first annual submission of risk management and compliance programmes (RMCPs) under FIC Directive 12 was Friday 9 October 2026. If your practice falls in one of the listed categories and you did not submit, you are now late.
On deadline day the FIC issued a notice to the institutions in Schedule 1 items 1, 2, 9 and 11 of the FIC Act. Item 2 is trust and company service providers. Accountants who form companies for clients, act as a registered office or provide nominee services fall under item 2.
The step that stopped submissions
The FIC's notice dealt with one problem. Step 5 of the online submission asks for a comment. If the comment box is empty, the submit button stays inactive. The FIC says: "Only once a comment is inserted may RMCPs be submitted."
If you tried to submit and the button would not work, this is the likely reason. Type a short comment and try again.
How you know it worked
The FIC will send an acknowledgement of receipt once it has your RMCP. If you have no acknowledgement, assume the FIC does not have your submission. Keep the acknowledgement on your compliance file.
If you missed the deadline
The FIC's notice does not say how it will treat late submissions. Institutions that have not submitted can take these steps:
Submit your RMCP now, with a comment at step 5.
Keep a record of when you submitted and why it was late.
Log a compliance query with the FIC explaining the delay, or call the FIC on 012 641 6000.
Save the acknowledgement when it arrives.
Remember that submitting your RMCP does not mean the FIC has approved it. The obligation to apply the RMCP in your practice every day has not changed. Our Directive 12 article explains who must submit and what to upload.
CIBA members can find an RMCP template in their member profile, or enrol in the FIC Compliance for Accountable Institutions short course.
