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 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.
The agenda in one page
Four priorities. Five moves.
- 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.
- The new beneficial-ownership disclosure module increases law-enforcement visibility. Reconcile records instead of assuming that a filing receipt proves their accuracy.
- Refresh the governance reading pack and competence checks using the FSCA’s latest listed materials, without presenting publications as new legislation.
- 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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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 / trigger | Item | Status and follow-through |
|---|---|---|
| 9 October 2026 — passed | RMCP deadline for categories named by the FIC | Verify receipt or escalate the gap now; no extension assumed. FIC: RMCP submission reminder · 9 October |
| 29–30 October 2026 — provisional | Technical Annexure C workshops | For 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.
- FIC: RMCP submission reminder · 9 October
- CIPC / the dtic: beneficial-ownership disclosure module · 29 September
- FSCA: announcement of the 2025/26 Integrated Report
- FSCA: Fit and Proper — September 2026 recognised-qualifications listing
- National Treasury: technical Annexure C proposals for the 2027 Budget · 4 September
- 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.