The Financial Sector Conduct Authority (FSCA) has released its Explanatory Guide to the Omni-Risk Return, which explains what data financial institutions will need to provide and how this new return fits into the FSCA’s broader Integrated Regulatory Solution (IRS).
Why the update?
Following concerns that the reporting requirements in FSCA’s proposed Omni-CBR would place too much of a burden on financial institutions, the regulator developed a simpler, phased approach – the Omni-Risk Return. This new return streamlines reporting while still giving the FSCA the information it needs to assess risk and strengthen oversight. It will feed into the automated risk model within the IRS and form the foundation of the FSCA’s future risk-based supervision model.
The Omni-Risk Return aims to reduce duplication, simplify reporting and create one consistent risk profile for each institution, taking into consideration the size and complexity of different businesses, ensuring supervision is fair and proportionate.
Implementation will take place gradually, in line with the IRS rollout, which is expected from 2026, giving institutions time to prepare their systems and data.
How the data will be used
The FSCA has proposed that the Omni-Risk Return be submitted once a year, though this may change. The data collected will help the FSCA understand risks within the financial sector and identify where intervention is needed. Specifically, it will be used to:
- Build a risk profile for each institution to determine how closely it needs to be supervised.
- Identify early warning signs of potential governance, internal control or conduct issues.
- Compare institutions across the sector to spot trends and outliers.
- Focus supervisory efforts where risks are highest.
- Help shape future regulation and guidance based on the evidence collected.
At Masthead’s recent Cape Town MasterClass event, FSCA’s Head of Supervisory Framework, Loraine van Deventer, confirmed that every data point collected serves a purpose and will be used in the FSCA’s assessment of risk. This highlights why accuracy and completeness are essential for every submission.
What information will be required
The Omni-Risk Return consists of 12 sections, each designed to give the FSCA a clearer understanding of a financial institution’s operations and risks:
- Group structure, ownership and shared services – information about ownership, shareholding and group dependencies.
- Geographical presence – where the institution operates and any cross-border exposure.
- Governance – governance arrangements, risk tolerance, remediation and insurance coverage.
- Nature of customer base and politically exposed persons (PEPs) – client base, vulnerability and anti-money laundering and combating the financing of terrorism (AML/CFT) exposure.
- Handling of customer assets – fiduciary responsibilities, fund collection and unclaimed assets.
- Transaction volumes and distribution – sales channels, intermediaries and market exposure.
- Product and agreement terminations – product cancellations, surrenders and early withdrawals.
- Advertising and communication – marketing practices and customer disclosures.
- Complaints management – complaint volumes, resolution processes and outcomes.
- IT and data governance – technology resilience, cybersecurity and data integrity.
- Outsourcing and organisational capacity – staffing levels, training and external service providers.
- Financial data – revenue, expenditure and overall financial soundness.
Not all sections apply to every institution, but each must be able to provide accurate, reliable data where relevant.
Moreover, a key feature of the Omni-Risk Return is a declaration by senior management confirming that the submitted information is accurate and complete.
How Masthead is helping clients prepare
For the past two years, Masthead has been helping clients prepare by focusing on data readiness, outcomes-based supervision and Treating Customers Fairly (TCF) during client discussions. Building on this, we are taking practical steps to support clients with the new Omni-Risk Return by:
- Reviewing the Omni-Risk Return to identify areas where clients may need additional support.
- Running a centralised project to test the new requirements across different types of FSPs and financial institutions, providing a clearer view of how the framework could affect various businesses.
- Inviting members to send comments and ongoing feedback through Masthead, allowing us to consolidate and submit feedback to the FSCA as part of a coordinated industry response.
Preparing for a data-driven future
The FSCA’s move toward the Omni-Risk Return marks a new phase in regulatory supervision – one that places greater emphasis on data quality, transparency and accountability.
At Masthead, our goal is to help our clients strengthen their systems, ensuring they are compliant and positioned for long-term success. For more information on the Omni-Risk Return, contact your Masthead Compliance Officer or get in touch with us.
Click here to view the Omni-Risk Return documents.