Held an ICPAC ASP licence on 31 December 2025? A new annual questionnaire is yours to file unless two things were both true last year: no ASP income and no ASP clients. A year with no income alone does not get you out. One zero is not enough.
Compliance Circular 27/2026, issued on 03 September 2026 to all ASP firms of the Institute and all their compliance officers, opens the Annual Geographic Exposure Questionnaire for the year 2025. The circular says the Questionnaire introduces a new annual reporting obligation for all firms holding an ASP Licence. It is released for completion and submission through the ICPAC Data Portal on 15 September 2026, and a separate personalised notification is issued on release.
On who is caught, the circular gives two halves that pull against each other. The obligation applies to ALL ASP licensed firms, irrespective of their level of ASP activity or income during the reporting year. Submission is mandatory for all active firms holding an ASP licence as at 31 December 2025.
Activity and income are irrelevant, says the first half. The second half hangs the duty on one word, active, and the circular never defines it. The Guidance Notes define its opposite.
They say the requirement relates to all ASP licensed firms, irrespective of whether they were practising in their professional capacity or they were dormant in the effective year and irrespective of whether they belong in a group of companies, which is also required to submit the Questionnaire. In plainer words: a dormant year does not excuse you, and neither does sitting inside a group, which the Guidance Notes describe as also required to submit the Questionnaire.
The single door out is in a bracket. If the ASP license is not active, which the Guidance Notes gloss as no income and no clients, the Non-Administration Services Practicing Declaration must be completed and submitted by email to ICPAC's compliance address. If that declaration was already submitted as part of the AML/CFT and Sanctions Questionnaire 2025, there is no need to resubmit it.
ICPAC's own preparation template shows the shape of that door. It asks the firm to pick one of three statuses: no ASP clients and no ASP-related income, where the template says there is no requirement to complete the Questionnaire; ASP clients with no ASP-related income; or active, meaning ASP clients and ASP-related income. The middle status is a filing status. Billing nothing all year is not the exit.
What gets filed is a headcount by country. Three questions count people and entities: natural persons, being clients and clients' beneficial owners, by country of residence; clients that are legal entities, partnerships, trusts and other legal arrangements, by country of registration, with redomiciled entities reported by country of redomiciliation; and PEP clients and PEP beneficial owners, by country of residence. Residence for the natural persons, registration for the entities, and the two are not interchangeable. Three further questions ask about the ASP itself and not its clients: countries of presence, countries of its own banking activity, countries of business promotion, such as introducers, agents or alliances. The template's country list runs to 193 entries.
Two dates are in circulation. The circular says completed Questionnaires must be submitted no later than 30 October 2026. The Guidance Notes say the information must be submitted on an annual basis, with a submission deadline of 31 October each year, and Circular 3/2026 back in February said 31 October 2026. Work to the earlier one and the conflict never reaches you.
The consequence sentence carries no discretion. Failure to submit the Questionnaire on time will prevent ICPAC from meeting its compliance requirements and will therefore inevitably give rise to enforcement actions against the firm.
The preparation language is softer. Firms are encouraged to begin preparing in advance and strongly advised to review the Guide thoroughly before completing the Questionnaire. The template is for preparation only and must not be submitted to ICPAC.
So check the status box before you check the calendar. A quiet year is still a filing year, and the only firm that walks away is the one with no income and no clients, and even that firm has a declaration to send.
Not legal advice. Verify against the primary source before acting.
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