FIC reporting deadlines in South Africa — CTRs, STRs and the annual Risk and Compliance Return

An accountable institution has one date-driven deadline a year — the Risk and Compliance Return — and two event-driven ones that start the moment something happens. Cash above R49,999.99 triggers a cash threshold report. A suspicion triggers a report that must reach the Centre as soon as possible and no later than 15 business days after you become aware of the fact.

Reviewed by TefCo Compliance Research — last verified 7 September 2026.

In short

Cash threshold: R49,999.99 aggregated, reported under the Financial Intelligence Centre Act 38 of 2001, section 28.
Suspicious transactions: as soon as possible, no later than 15 business days (section 29).
The 2026 Risk and Compliance Return window opened 4 May 2026 and closed 30 June or 31 July 2026 depending on the category of business.
Registration with the Centre must be under the correct Schedule 1 item number (section 43B).

The three reports and their clocks

FIC reporting obligations
Report	Trigger	Deadline	Source
Cash threshold report (CTR)	Cash above R49,999.99, aggregated	On the reporting standard set by the Centre	FIC Act 38 of 2001, section 28
Suspicious transaction report (STR)	Becoming aware of a suspicious or unusual fact	As soon as possible, max 15 business days	FIC Act 38 of 2001, section 29
Terrorist property report (TPR)	Property linked to a listed person or entity	Immediately on becoming aware	FIC Act 38 of 2001, section 28A
Risk and Compliance Return (RCR)	Annual, where the Centre directs	2026 window: 4 May to 30 June / 31 July	FIC Directive 11 of 2026

The 15 business days for an STR exclude Saturdays, Sundays and public holidays.

The Risk and Compliance Return is the one people miss

The RCR is issued by directive, not by a standing date in the Act, so the window moves. For 2026 the Centre gazetted Directive 11 on 31 March 2026, opened submissions on Monday 4 May 2026 and closed them on 30 June or 31 July 2026 depending on the institution's category of business.

Because the directive names the categories it applies to, the first question each year is not 'when' but 'does it apply to us this year'. Check the directive, not last year's habit.

The Centre publishes the RCR window and closing dates by media release each year. Diarise a check in March rather than waiting for a notification.

Registration under the right item number

Every accountable institution in Schedule 1 and every reporting institution in Schedule 3 must register with the Centre under the Financial Intelligence Centre Act 38 of 2001, section 43B. In August 2025 the Centre issued a notice specifically about institutions registered under the wrong Schedule 1 item number — the wrong item means the wrong obligations and the wrong supervisory body.

Beneficial ownership sits alongside, not inside, the FIC Act

The CIPC beneficial ownership register is a Companies Act obligation, not a FIC Act one, but it is where most AML reviews start. Newly registered entities file beneficial ownership information within 10 business days of registration, and then annually on the anniversary date even where nothing has changed.

Frequently asked

Is the R49,999.99 threshold per transaction?

It applies to cash above that amount, including aggregated transactions. The Centre's cash threshold reporting guidance sets out how aggregation works — smurfing a payment into smaller amounts does not avoid the report.

What are the penalties under the FIC Act?

Offences under the Financial Intelligence Centre Act 38 of 2001, section 68, carry imprisonment of up to 15 years or a fine of up to R100 million for the general category of offences. Administrative sanctions from supervisory bodies are far more common than prosecutions.

Do we file an RCR every year?

Only when a directive says your category must. The Centre issues a new directive for each cycle and names the categories it covers.

Sources

TefCo Corporate Compliance (Pty) Ltd is a compliance management platform, not a legal, tax or advisory firm. This guide is general information, not advice. Fees, dates and thresholds change — confirm current figures with the regulator before you rely on them.