FCA Non-Financial Misconduct Compliance Check

Why this matters

From 1 September 2026, the FCA’s expanded rules on non-financial misconduct (NFM) come into force, bringing serious workplace bullying, harassment and violence explicitly within the scope of the Conduct Rules (COCON) for around 37,000 solo-regulated firms — not just banks and insurers, but mortgage brokers, insurance intermediaries, financial advisers, consumer credit firms, payment and e-money institutions, and asset managers. A new rule, COCON 1.1.7FR, makes bullying, harassment or violence against colleagues a breach of Individual Conduct Rule 1 (acting with integrity) wherever it relates to a person’s role, and — unlike Equality Act harassment — this does not need to relate to a protected characteristic, so the potential scope is considerably wider than existing discrimination law.

The change also affects how firms handle regulatory references: employers will need to disclose serious, substantiated NFM findings — including relevant conduct in personal life or on social media — when references are requested for departing staff moving to another regulated firm. For small and mid-sized FCA-authorised firms this means updating conduct, disciplinary, whistleblowing and reference policies, retraining staff and Senior Managers under SM&CR, and making sure any past or ongoing misconduct cases are handled and documented in a way that would withstand FCA scrutiny. Firms that haven’t reviewed their culture and conduct framework before the 1 September deadline risk falling short of both the letter of COCON and the FCA’s stated expectation of firms actively fostering healthy workplace cultures.

What you'll need

• Whether your business holds any FCA authorisation or permission, and what type
• Whether Senior Managers & Certification Regime (SM&CR) applies to your firm
• Your existing conduct, disciplinary, whistleblowing and reference policies
• Approximate staff headcount and whether you've had any bullying, harassment or violence complaints in the last 12 months

What you'll get

A personalised compliance report covering: a score out of 100, an executive summary, a list of findings ranked by severity, and a prioritised action plan with timeframes.