For customers

Twelve FICA Myths, Corrected

Almost everyone in South Africa has been FICA'd. Almost everything people believe about it comes from rules repealed in 2017 — or rules that never existed.

Published Last reviewed 8 min read

Legal position stated as at 11 June 2026

Written by

Martin Kotze

Attorney, Conveyancer & Notary Public

Quick answer

Most of what South Africans “know” about FICA — the green bar-coded ID book, the municipal account not older than three months, certified copies, IDs for every director and shareholder, the 25% rule — is not in the Financial Intelligence Centre Act. Most of it comes from regulations repealed on 2 October 2017, from old bank checklists that outlived the rules they were based on, and from habit. The Act was amended again in December 2022, and the FIC’s core guidance was rewritten in 2025 — so even fairly recent summaries are out of date. Each correction below states the current legal position with its source.

Each card states the myth, then the actual position under the Act, the Regulations or the FIC’s own guidance — with the pinpoint source. Where a full guide exists, follow the link.

FICA requires a green bar-coded ID book.

The actual position

No ID format is prescribed. Smart ID cards, the old book, passports, driver’s licences and permits are all acceptable sources, as is electronic data. Even pre-2017, the “green bar-coded” gloss came from guidance describing Home Affairs practice, and alternatives were allowed.

GN 7A para 88; GN 3A (withdrawn)What verification actually means

Proof of address not older than 3 months is a FICA requirement.

The actual position

Address verification was a regulation only until 2 October 2017; the 3-month figure was never in the regulation at all — it was a “good practice” suggestion in 2005 guidance. Today an address is an optional supplementary attribute. If asked for, it is the institution’s RMCP choice.

Former reg 3 (repealed); GN 3A; GN 7A para 86The proof-of-address guide

There is an official list of FICA documents.

The actual position

There has been no statutory document list since 2 October 2017. Each institution’s Risk Management and Compliance Programme sets its own.

GN R1062 of 2017; FIC Act ss 21(1), 42What documents FICA actually requires

Verification means the institution checks your ID with Home Affairs.

The actual position

A Home Affairs database check is one encouraged method, not a mandate. Verification means corroborating identity information against any reliable, independent source — documentary or electronic.

GN 7A paras 83, 88–94

Someone must physically compare your face to the ID photo.

The actual position

Not required by any provision. Photo comparison is a common RMCP method face-to-face; biometric or data-based corroboration is equally valid, and fully remote onboarding is lawful.

GN 7A paras 82–91Online and biometric FICA

For a company you need IDs and proof of address of all directors.

The actual position

Directors as such need not be identified at all — only the person acting for the client, beneficial owners, and (as a last resort) senior management. Proof of address for directors appears nowhere.

FIC Act ss 21(1)(c), 21B(2); GN 7A para 98FICA for companies

If a shareholder is a company, you must FICA its directors and shareholders, and theirs, forever.

The actual position

You look through corporate layers, multiplying ownership percentages, to find the natural persons at the top; failing that, the client’s senior management. Layers supply structure information only — the chain is always finite.

FIC Act s 21B(2)(a); PCC 59 paras 2.9, 2.32; GN 7A para 105The beneficial-ownership cascade

The 25% shareholder rule is in the Act.

The actual position

No percentage appears in the Act or Regulations. 25% was guidance (2017–2025), removed in September 2025; the FIC now strongly recommends treating 5%+ as a controlling ownership interest.

PCC 59 paras 2.16–2.18; Revised GN 7A (2025)25% or 5%? Settled

Once FICA’d at one bank, you’re FICA’d everywhere.

The actual position

Each institution carries its own duty; nothing makes one institution’s customer due diligence binding on another. An RMCP may allow reliance on another institution’s CDD, but responsibility stays with the relying institution.

FIC Act s 21; PCC 12A

My bank asking for documents again is unlawful harassment.

The actual position

Ongoing due diligence is a statutory duty: information must be kept up to date, and CDD must be repeated when doubts arise. Frequency is set by the RMCP.

FIC Act ss 21C(1)(b), 21DYour rights when asked for FICA

POPIA lets me refuse to hand over FICA information.

The actual position

Processing personal information to comply with FICA is lawful; the FIC says FICA provides the legal justification under POPIA. Refuse, and the institution must decline or end the relationship.

PCC 22A; FIC Act s 21EPOPIA and FICA

The FIC will phone you and charge a fee to “release” funds.

The actual position

Always a scam. The FIC never demands payments from the public and does not freeze ordinary accounts; report impersonation to scams@fic.gov.za.

FIC Scams AwarenessFICA scams guide

Why so many myths?

Until 2 October 2017 the regulations really did prescribe documents — so a generation of checklists was built on them. When the prescriptive chapter was repealed and replaced with the risk-based approach, the checklists survived the rules they were based on. The Act was then amended again in December 2022, the FIC’s beneficial-ownership position changed in August 2024 (PCC 59), and the core guidance was rewritten in September 2025 — removing the famous 25% indicator entirely. Each wave left more out-of-date summaries behind. Every page in this hub states the position as at the date shown at the top, with the source cited.

Why you can trust this: Martin Kotze has been an admitted Attorney of the High Court of South Africa, registered Conveyancer, and Notary Public since 2014, practising from Pretoria. The firm is regulated by the Legal Practice Council under firm registration F17333.

This guide is general information, not legal advice for your specific matter.

Need more than a guide?

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We advise companies, trusts and accountable institutions on customer due diligence, beneficial ownership and RMCPs — and we run this regime in our own practice every day.