Only Schedule 1 institutions carry FICA duties
FICA works through a closed list. Sections 20A–21H (customer due diligence), section 42 (the RMCP), section 43B (registration) and the reporting duties all attach to “accountable institutions” — defined as the institutions in Schedule 1. The Schedule was substantially rewritten by GN 2800 (GG 47596 of 29 November 2022), with effect from 19 December 2022.
The current list (from 19 December 2022)
| Sector | Notes |
|---|---|
| Legal practitioners | Practitioners as defined in the Legal Practice Act — including every conveyancer. Item 1. |
| Trust and company service providers (TCSPs) | Includes accountants and agents providing company-secretarial or trust services — a 2022 expansion that caught many practices by surprise. |
| Estate agents / property practitioners | As defined in the Property Practitioners Act; supervised via the PPRA. |
| Banks, mutual banks and co-operative banks | The classic accountable institutions. |
| Life insurers | Long-term insurance business. |
| Financial services providers and CIS managers | FSPs advising/intermediating on investments and collective investment scheme managers. |
| Foreign exchange and money or value transfer providers | Including informal MVTS providers since 2022. |
| Gambling licensees | Casinos and licensed gambling operations. |
| Credit providers | A wider category since 2022 — beyond NCA-registered lenders. |
| Crypto asset service providers (CASPs) | Exchanges, custodians and related services — new from 19 December 2022. |
| High-value goods dealers | Any dealer receiving R100 000 or more for an item, in any payment form — how car and Krugerrand dealers are caught. Item 20. |
| The South African Mint, Postbank and payment clearing participants | State and payment-system entities added in 2022. |
The table is a plain-language summary — the authoritative wording is in the Schedule itself (GN 2800 amendment notice), summarised with sources in the source library.
The 2022 newcomers
The rewrite’s practical shock was who it added: company-secretarial and trust service providers (many accounting practices), a much wider class of credit providers, crypto asset service providers, and high-value goods dealers — the item that turned car dealerships, jewellers and art dealers into accountable institutions for any R100 000+ transaction in any payment form. Schedule 3’s lighter “reporting institution” category was abolished at the same time. Sector guides: high-value goods dealers and crypto.
If you are not on the list
A business outside Schedule 1 carries none of FICA’s customer due diligence duties — whatever its forms say. (Forms demanding “FICA documents” from suppliers or tenants are usually risk management borrowed from banking practice, not a statutory obligation.) The anonymity rule is the one near-universal exception: an accountable institution may never deal with an anonymous client, and prudent non-accountable businesses follow the same logic voluntarily.
Frequently asked questions
Only if a Schedule 1 item describes what you do. The most commonly missed catches since December 2022: providing company-secretarial or trust services (TCSP), providing credit, dealing in items worth R100 000+ (vehicles, jewellery, art), and crypto services. If an item fits, registration with the FIC and an RMCP follow — see running an accountable institution.
If a Schedule 1 item covers your activity, yes. Accountable-institution status turns on what you do, not on whether you accept cash — and for high-value goods dealers the FIC's guidance (PCC 58) confirms the R100 000 threshold counts any payment form, not just cash. (This exact question appears on the FIC's own FAQ.)
Schedule 3 (reporting institutions — previously motor dealers and Krugerrand dealers with lighter duties) was abolished in the 2022 rewrite. Those sectors now enter Schedule 1 as high-value goods dealers when the R100 000 threshold is met, with full accountable-institution duties.