What Directive 12 Changes for Your Firm
Until now, many firms have treated the RMCP as a document that simply needed to exist and be kept on file.
Directive 12 changes that position.
By 9 October 2026, legal practitioners are required to submit the RMCP contemplated in section 42 of the FIC Act to the FIC.
That makes an important distinction relevant:
Section 42 determines what that RMCP is required to address.
Through our work reviewing RMCPs and supporting law firms with FIC inspections, we have seen an important gap:
A firm may have an RMCP on file without that document necessarily reflecting the firm’s actual compliance framework.
During our RMCP reviews and while supporting law firms through FIC inspections, some of the issues we have observed include:
- RMCPs that are generic rather than firm-specific
- procedures in the RMCP that do not match what the firm actually does in practice
- documents that have not kept pace with changes in the firm’s clients, services or risk exposure
- compliance controls that exist in practice but are not properly reflected in the RMCP — or vice versa
The existence of an RMCP does not, on its own, tell you whether the document adequately reflects your firm or addresses the requirements of section 42.
In other words:
Directive 12 therefore changes the question from:
to:
That is the question worth answering before the document reaches the FIC.
In the presentation, we will unpack what section 42 requires your RMCP to address, where gaps can arise, and what firms should be testing in their own documents before submission — including what we can learn from an RMCP that passed FIC review and an actual FIC inspection report.
