South African regulatory intelligence · Issue 05

Prove completion. Close the gaps.

The current executive agenda: confirm RMCP receipt, reconcile beneficial ownership and prepare evidence-led follow-through for the rest of October.

October 2026 · catch-up updatePublished: 16 October 2026Content cutoff: 13 October 2026

October catch-up edition. Published 16 October 2026, following Issue 04. Content cutoff: 13 October 2026; included sources and deadlines rechecked for release on 16 October. The 9 October RMCP deadline has passed; the 29–30 October workshops remain subject to invitation.

05

The agenda in one page

Four priorities. Five moves.

  1. The FIC’s 9 October RMCP deadline has passed for the specified Schedule 1 categories. Verify actual receipt; a saved document is not proof of submission.
  2. The new beneficial-ownership disclosure module increases law-enforcement visibility. Reconcile records instead of assuming that a filing receipt proves their accuracy.
  3. Refresh the governance reading pack and competence checks using the FSCA’s latest listed materials, without presenting publications as new legislation.
  4. Close expired consultations and prepare for the provisionally indicated 29–30 October technical-tax workshops if you submitted a proposal.

Priority developments

What to decide—and what to retain.

Each card distinguishes the source’s status from Cofi’s recommended action.

Immediate verificationFIC · submission requirement and operational reminder

RMCP: look for the acknowledgement.

The FIC’s 9 October reminder names Schedule 1 items 1, 2, 9 and 11 and a submission deadline of that day. It says Step 5 requires a comment before submission is enabled, and receipt triggers an acknowledgement.

Executive move

For an entity in scope, locate that acknowledgement and match it to the submitted RMCP. If evidence is absent, investigate promptly and contact the FIC about the remedial route. Do not assume an extension or apply the reminder to every business indiscriminately.

Suggested owner: AML compliance officer / accountable executive
Evidence: Applicability record, submitted version, acknowledgement and any escalation trail.

Ownership transparencyCIPC / the dtic · operational capability

Make ownership evidence consistent across systems.

The 29 September announcement describes a beneficial-ownership disclosure module for accredited law-enforcement users. It supports access to ownership information and documents; it does not announce unrestricted public access or a new universal filing deadline.

Executive move

Sample complex structures and reconcile the company’s filings, ownership chart and supporting documents. In customer due diligence, investigate discrepancies through authorised processes; do not assume that an FSP has the same access as law enforcement.

Suggested owner: Company secretary / financial-crime team
Evidence: Reconciliation, discrepancy log and documented corrections.

Governance readingFSCA · published report announcement

Update the board’s regulatory reading pack.

The FSCA announces its 2025/26 Integrated Report, covering the year ended 31 March 2026. The announcement confirms publication; this brief does not attribute detailed findings to the report without examining the underlying text.

Executive move

Assign a reviewer to obtain the report and identify implications for the institution’s own governance and supervision agenda. Distinguish what the report actually says from management’s interpretation. Record actions only after the source passage is checked.

Suggested owner: Compliance head / board secretary
Evidence: Source-linked reading note, board discussion and assigned actions.

Competence controlsFSCA · recognised-qualifications listing

Check the current qualification evidence.

The FSCA’s Fit and Proper page lists a September 2026 recognised-qualifications version. The presence of an updated list does not, on its own, establish that a particular qualification has been added, removed or accepted for every category.

Executive move

Before a recruitment or representative-status decision, check the precise qualification and relevant category against the official list. Retain the source version and decision. Assess other applicable competence requirements separately; a qualification check is not the whole assessment.

Suggested owner: Key individual / HR / compliance
Evidence: Dated qualification check, category match and supporting competence file.

Forward calendarTreasury · workshops subject to invitation

Prepare for the technical-tax follow-up.

Treasury indicated virtual workshops on 29 and 30 October for those who submitted technical Annexure C proposals, with dates to be confirmed by electronic invitation. Participation or further engagement does not guarantee inclusion in the 2027 Budget.

Executive move

If a submission was made, check the invitation and prepare concise factual examples. Nominate an attendee and record questions. If no proposal was submitted, do not represent attendance as confirmed.

Suggested owner: Finance / tax adviser
Evidence: Invitation, attendee brief and post-workshop action note.

Legislative watchParliament · Bill, not an operative amendment

Keep AML reform on the watchlist, not in the law column.

Parliament’s published B15–2026 is an AML and counter-terrorism-financing amendment Bill. The material checked for this edition does not establish enactment or commencement; this brief does not assign an unverified later parliamentary stage.

Executive move

Maintain a change-impact log and watch official progress. Separate planning for possible amendments from compliance with existing obligations. Before changing a mandatory control or deadline, verify the final instrument and its commencement provisions.

Suggested owner: Legal / compliance policy lead
Evidence: Versioned legislative watch entry and approved applicability assessment.

Regulatory calendar

Dates with the right context.

Date / triggerItemStatus and follow-through
9 October 2026 — passedRMCP deadline for categories named by the FICVerify receipt or escalate the gap now; no extension assumed.
FIC: RMCP submission reminder · 9 October
29–30 October 2026 — provisionalTechnical Annexure C workshopsFor submitting stakeholders; confirm the invitation before committing.
National Treasury: technical Annexure C proposals for the 2027 Budget · 4 September

Follow-through

A control is only complete when its evidence is retrievable.

Keep urgency separate from publication. An institution affected by a missed filing should address it immediately through its compliance owner; it should not wait for this newsletter’s release. For the next governance meeting, show completed evidence, unresolved exceptions and a named owner for each remaining item.

Need help translating the brief into an action register? Contact Cofi Compliance.

Sources and scope

Read the official material.

  1. FIC: RMCP submission reminder · 9 October
  2. CIPC / the dtic: beneficial-ownership disclosure module · 29 September
  3. FSCA: announcement of the 2025/26 Integrated Report
  4. FSCA: Fit and Proper — September 2026 recognised-qualifications listing
  5. National Treasury: technical Annexure C proposals for the 2027 Budget · 4 September
  6. Parliament: General Laws (Anti-Money Laundering and Combating Terrorism Financing) Amendment Bill B15–2026

General regulatory information for South African financial-sector readers, not legal, tax or investment advice. Applicability depends on the institution, activities and operative instruments. Proposed actions and owners are Cofi editorial recommendations, not additional regulatory requirements. Official sources take precedence. Content cutoff: 13 October 2026. Included source links and status labels rechecked for release on 16 October 2026.

South African regulatory intelligence · Issue 04

Close September’s control gaps.

Insurance benefit adjustments, consultation close-outs and filing readiness: the September briefing, reconstructed for a transparent catch-up release.

September 2026Published: 15 October 2026Content cutoff: 24 September 2026

Retrospective catch-up edition. Originally due 28 September 2026, covering sources published by 24 September. This is not a copy of an edition sent in September. Dates below retain their historical context; passed deadlines are labelled. Read Issue 05 alongside it for the current position.

04

The agenda in one page

Four priorities. Five moves.

  1. Reconcile health-insurance benefit information with Treasury’s annual demarcation adjustments before reusing product or advice material.
  2. Separate proposed policy from existing duties: cross-border crypto and unclaimed-assets proposals require tracked decisions, not premature implementation.
  3. Bring the FIC’s September RMCP submission notice into the compliance calendar and check the operative instruction for the entity concerned.
  4. Fix administrative weak points: controlled CIPC contact details, a reliable registered office and evidence of any September consultation submissions.

Priority developments

What to decide—and what to retain.

Each card distinguishes the source’s status from Cofi’s recommended action.

Product governanceTreasury · annual benefit adjustments

Align benefits and customer-facing material.

Treasury’s 1 September statement announces the 2026 annual benefit escalations under the insurance demarcation regulations. These adjust specified benefits; they are not a new, stand-alone health-insurance regime.

Executive move

For affected products, compare the official tables with policy schedules, quote tools and adviser scripts. Resolve discrepancies with the insurer before changing customer documents. Do not assume every insurance product is in scope.

Suggested owner: Product / compliance lead
Evidence: Signed comparison, affected-document list and approved corrections.

Consultation close-outTreasury / SARB · draft framework

Keep cross-border crypto proposals separate from permissions.

The draft Crypto Asset Manual proposes a framework for cross-border crypto activity. Comments were due by close of business on 30 September. The proposals should not be treated as authorisation to provide a service.

Executive move

Record relevant cross-border activities, dependencies and any submission made. For this catch-up release the deadline has passed: retain proof of response or record that none was made, then monitor the final instruments.

Suggested owner: Legal / crypto business lead
Evidence: Applicability note, approved response if submitted and policy watch entry.

Policy watchTreasury · discussion proposal

Make unclaimed-asset records usable now.

Treasury proposed centralising aspects of unclaimed financial assets, including administration and tracing. The comment period closed on 19 September, before this edition’s original research cutoff. The proposal is not itself an instruction to transfer assets.

Executive move

Where relevant, reconcile dormant balances, ownership records and tracing attempts. Keep any consultation response on file. Identify operational dependencies without implementing a proposed transfer model as though it were enacted.

Suggested owner: Operations / fund or product administrator
Evidence: Reconciled inventory, tracing log and recorded policy assessment.

Submission readinessFIC · published Directive 12 web notice

Put RMCP submission responsibility on the record.

The FIC published a web notice on 4 September concerning Directive 12 and submission of risk management and compliance programmes. The notice’s existence is verified; detailed obligations must be checked against the operative instrument.

Executive move

Name the submission owner and have them confirm the entity’s coverage, required version and deadline directly with the FIC material. This retrospective card does not backfill later guidance into September. Issue 05 covers the verified 9 October reminder.

Suggested owner: AML compliance officer
Evidence: Applicability decision, controlled RMCP version and submission record.

Corporate recordsCIPC · operational notices

Keep the company reachable—and the profile controlled.

September CIPC notices address unique email and cellphone details for customer profiles and the accuracy of registered-office information. Treat portal contact controls and the company’s registered address as separate records requiring named ownership.

Executive move

Test access to the correct profile, remove dependencies on departed staff and check where official correspondence is delivered. Use authorised, controlled contact details; do not solve a duplicate-contact error by borrowing someone else’s credentials.

Suggested owner: Company secretary / authorised administrator
Evidence: Verified profile contacts, address check and correction confirmations.

Tax inputTreasury · invitation, not tax law

Close out technical tax proposals.

The invitation sought technical issues for Annexure C of the 2027 Budget; submissions closed on 30 September. It did not announce new tax rates or enacted amendments.

Executive move

Finance should file the final response and proof of submission, or record a decision not to participate. Keep unresolved technical problems in the internal tax-risk register. Issue 05 carries the later workshop follow-through.

Suggested owner: Finance / tax adviser
Evidence: Submission pack or non-participation decision and supporting examples.

Regulatory calendar

Dates with the right context.

Date / triggerItemStatus and follow-through
19 September 2026Unclaimed-assets consultation closedAlready closed at the original cutoff. Retain any submission; do not imply the window remains open.
National Treasury: proposed framework for unclaimed financial assets · 20 August
30 September 2026Crypto Manual comments dueFuture at the original cutoff; now passed. No extension is assumed.
National Treasury / SARB: draft cross-border Crypto Asset Manual · 3 August
30 September 2026Technical Annexure C proposals dueFuture at the original cutoff; now passed.
National Treasury: technical Annexure C proposals for the 2027 Budget · 4 September
Before catch-up publicationRecheck links and later developmentsEditorial release gate, not a regulatory deadline. Use Issue 05 for subsequent developments.

Follow-through

Recover the evidence, not just the timetable.

Do not reopen a closed deadline in customer communications. Complete one exception register: action, accountable person, original due date, present status and evidence. Where a filing may have been missed, escalate it to the responsible compliance officer rather than treating this delayed newsletter as an extension.

Need help translating the brief into an action register? Contact Cofi Compliance.

Sources and scope

Read the official material.

  1. National Treasury: 2026 demarcation benefit adjustments · 1 September
  2. National Treasury / SARB: draft cross-border Crypto Asset Manual · 3 August
  3. National Treasury: proposed framework for unclaimed financial assets · 20 August
  4. FIC: Directive 12 RMCP submission web notice · 4 September
  5. CIPC: unique email and cellphone validation · 14 September
  6. CIPC: registered-office address reminder · 7 September
  7. National Treasury: technical Annexure C proposals for the 2027 Budget · 4 September

General regulatory information for South African financial-sector readers, not legal, tax or investment advice. Applicability depends on the institution, activities and operative instruments. Proposed actions and owners are Cofi editorial recommendations, not additional regulatory requirements. Official sources take precedence. Sources checked on 13 October 2026; links and legal status must be refreshed before release.

South African regulatory intelligence

Know what changed. Decide what to do next.

A concise executive brief that turns current regulatory developments into deadlines, accountable actions and evidence to retain.

Issue 03 23 August 2026 Sources verified 23 August 2026

Executive Regulatory Brief

The August control agenda in one page.

  1. 01

    The FSCA's 2025/26 Regulatory Actions Report turns enforcement trends into a board-level control-testing agenda.

  2. 02

    AML Bill B15-2026 moved into post-submission committee work in August; Parliament still lists it as a Bill, not law.

  3. 03

    The FSCA's August responsible-investment report puts governance, operations, products, risk and disclosure under review.

  4. 04

    Money Smart Week runs from 24 to 30 August, creating a time-bound customer-education and communication control window.

Priority developments

What requires executive attention now.

Each item separates final requirements, proposed law, investigations and public warnings so that action is proportionate to legal status.

Board actionFSCA · Final report

Turn the enforcement report into control tests.

The FSCA published its 2025/26 Regulatory Actions Report on 31 July. Use the report as an evidence-led prompt to test whether supervision, governance and financial-crime controls work in practice.

Executive move Assign an owner, sample, due date and remediation route for each relevant control theme.
Open the official FSCA publications page
Track nowParliament · Bill, not yet law

Refresh the B15-2026 impact assessment.

Parliament scheduled public hearings for 11 August and National Treasury's response to submissions for 19 August. The official Bill page still lists the General Laws AML/CFT Amendment Bill at committee stage.

Executive move Update the clause tracker, assumptions and accountable owners without treating proposals as law.
Check the official Bill status
Investment governanceFSCA · Final report

Run a responsible-investment evidence review.

The FSCA's August report examines governance, operations and products, and risk and disclosure. Funds, asset managers and advisers should identify which findings touch their mandates and customer claims.

Executive move Link every responsible-investment claim to an approved mandate, control and retained record.
Open the official August report listing
Policy watchCabinet · Bill, not yet law

Map exposure to official financial benchmarks.

Cabinet approved introduction of the General Financial Laws Amendment Bill, 2026. It proposes a new Financial Sector Regulation Act chapter for the governance and regulation of official benchmarks.

Executive move Inventory benchmark use, methodology owners, data vendors, customer disclosures and fallbacks.
Read the official Cabinet statement
24–30 AugustNational Treasury · Campaign

Control customer education like regulated communication.

Money Smart Week is a financial-literacy campaign, not a new legal obligation. Participating FSPs should still apply normal approval, plain-language, record-retention and channel-governance controls.

Executive move Approve the audience, claims, calls to action, escalation route and final published evidence.
Read the official campaign statement
Digital conductFSCA · Public warnings

Keep impersonation controls in the monthly test pack.

Current FSCA warnings continue to show how impersonators misuse authorised firms' names and channels. Customers need a reliable way to verify the real entity before acting.

Executive move Test domain monitoring, reporting, takedown, customer warning and incident evidence.
Open current FSCA warnings

Regulatory calendar

Dates requiring an accountable owner.

DateDevelopmentAction
24–30 AugMoney Smart Week South Africa 2026Approve and retain evidence for participating communications.
31 AugInternal August evidence checkpointClose actions or record approved owners and revised due dates.
OngoingB15-2026 parliamentary processTrack amendments and update the legal-status register.
OngoingGeneral Financial Laws Amendment Bill, 2026Monitor introduction and assess benchmark exposure.

Source-led follow-through

Move from the brief to the supporting evidence.

Sources and disclaimer

Source status was checked on 23 August 2026. This publication provides general regulatory information and practical compliance guidance, not legal advice. Bills are not law until enacted and commenced. Confirm each development against the official source before acting.

South African regulatory intelligence

Know what changed. Decide what to do next.

A concise executive brief that turns current regulatory developments into deadlines, accountable actions and evidence to retain.

Issue 02 29 July 2026 Compliance review preview

Executive Regulatory Brief

The regulatory week in one page.

  1. 01

    The final 2026 FIC risk and compliance return deadline is 31 July at 17:00 SAST for four specified categories.

  2. 02

    The COFI Bill has reached Parliament, but remains a Bill and is not yet law.

  3. 03

    The AML Amendment Bill comment window closes at 12:00 on 10 August.

  4. 04

    Recent FSCA actions put fraud controls, permission checks and CFD operating models under the spotlight.

Priority developments

What requires executive attention now.

Each item separates final requirements, proposed law, investigations and public warnings so that action is proportionate to legal status.

Act nowFIC · Final requirement

Complete the 2026 FIC risk and compliance return.

Legal practitioners, estate agents, non-casino gambling institutions and high-value goods dealers should confirm scope, declarant authority, reporting periods and proof of submission.

Executive move Lock the submission evidence pack and record the accountable owner.
Open the FIC source watch
Act nowParliament · Bill, not yet law

Assess the AML Amendment Bill before the comment deadline.

Parliament invited written submissions by 12:00 on 10 August 2026, with public hearings scheduled for 11 August.

Executive move Assign legal and compliance owners to compare the Bill with current policies and data flows.
Open the multi-regulator watch
COFI readinessNational Treasury · Proposed law

Start five low-regret COFI readiness moves.

Map regulated activities, products, customer journeys, governance responsibilities and evidence while continuing to comply with the framework currently in force.

Executive move Create one inventory of activities, permissions, products and distribution arrangements.
Read the COFI status guide
Enforcement lessonFSCA · Final enforcement

Test governance around employee fraud and customer transactions.

Recent enforcement shows why firms should identify where one person can originate, approve, execute or conceal a customer transaction.

Executive move Test segregation, privileged access, exception reporting and loss escalation.
Open the FSCA source watch
SupervisionFSCA · Investigation, no findings

Review CFD permissions without prejudging investigations.

Map every entity in the CFD customer journey to the regulated activity it performs and the permission it relies on. An investigation does not itself constitute a finding.

Executive move Verify entity, product and service permissions against the operating model.
Review supervisory updates
Digital conductFSCA · Public warnings

Harden controls against impersonation and AI-trading scams.

Publish a canonical list of official domains and contact channels, verify platform entities independently and maintain an evidence-led takedown and customer-warning process.

Executive move Assign monitoring, evidence capture, takedown and customer communication owners.
Open current public warnings

Regulatory calendar

Dates requiring an accountable owner.

DateDevelopmentAction
31 JulFinal 2026 FIC RCR deadline · 17:00 SASTSubmit and retain the final evidence pack.
04 AugFSCA Enforcement Roadshow · JohannesburgCapture supervisory and enforcement themes.
10 AugAML Amendment Bill submissions close · 12:00 SASTApprove and submit any institutional response.
11 AugAML Amendment Bill public hearings · onlineMonitor issues raised and proposed changes.

Source-led follow-through

Move from the brief to the supporting evidence.

Sources and disclaimer

This publication provides general regulatory information and practical compliance guidance. It does not constitute legal advice. Bills are not law until enacted and commenced. Regulatory investigations and warnings do not necessarily constitute final findings. Confirm each development against its official source before acting.