FIC Draft Directive 12 proposes that estate agents submit a copy of their Risk Management and Compliance Programme to the FIC each year. The directive is not yet finalised. The proposed first submission date for estate agents is 30 September 2026.
The consultation closed on 21 August 2026. The FIC will confirm the effective date when the directive is formally issued.
Six things to know about the draft before acting on it.
Published for comment on 31 July 2026. The comment window closed 21 August 2026. The directive has not been finalised and is not yet in force.
Estate agents are in scope. Estate agents are a Schedule 1 item 3 accountable institution under the FIC Act. The draft names them. Other categories in scope include legal practitioners, credit providers, high-value goods dealers, and crypto asset service providers.
Annual submissions are proposed. Covered institutions would submit a copy of their RMCP to the FIC once a year. This is distinct from the Risk and Compliance Return, which is a self-assessment questionnaire.
The proposed first deadline for estate agents is 30 September 2026. This is the date in the draft. It is not confirmed until the directive is formally issued.
Submission is of the RMCP document itself. You submit the programme, not a questionnaire. An RMCP that does not meet the section 42 requirements of the FIC Act cannot be submitted as-is.
The obligation to have a compliant RMCP already exists. Section 42 of the FIC Act requires every accountable institution to have a Risk Management and Compliance Programme. Directive 12, if finalised, adds an obligation to submit it. It does not create the underlying obligation for the first time.
Identifying gaps in your RMCP takes time. Addressing them takes more. Starting a review in August leaves little room to act before 30 September.
The obligation under section 42 exists now. Estate agencies are required to have an RMCP that identifies their money laundering, terrorist financing, and proliferation financing risks, and sets out the policies, procedures, and controls to manage them. That obligation does not arise from Directive 12. It is already in force.
A review now tells you two things: whether your programme meets the section 42 standard, and whether it is ready to submit if the directive is finalised as drafted. If it is not, you have time to act. If it is, you are done.
We review your existing RMCP against section 42 of the FIC Act and the FIC guidance notes that apply to estate agents. You receive a written summary covering:
The review is advisory. We do not submit your RMCP to the FIC on your behalf, and we do not certify compliance. If remediation is needed, we provide a separate proposal before any work begins.
If you do not have an existing RMCP, tell us when you enquire. We can outline what building one from scratch would involve before you commit to anything.
If your firm completed the 2026 RCR using our free preparation worksheet, the RMCP review is the logical next step. The RCR assessed your controls against the FIC's questions. This review looks at the programme document those controls sit inside.
From initial enquiry to written findings in three steps.
Use the contact form to tell us your firm name and whether you have an existing RMCP. No preparation is needed at this stage.
We schedule a call of around 20 minutes to understand your situation and confirm what we need from you before starting the review.
We review your programme and deliver a written summary of our findings. If remediation is needed, we provide a separate proposal before any work begins.
The review and the findings session are free, with no obligation. If remediation follows, we quote it separately before starting.
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