Guide

Non-Financial Misconduct Compliance Guide for FCA Firms

Prepare your firm for the FCA's new non-financial misconduct requirements before they take effect.

Starting September 1, 2026, non-financial misconduct — including bullying, harassment, discrimination, and workplace violence — becomes a regulated conduct breach for approximately 37,000 non-bank financial services firms. The FCA is extending conduct rules that previously applied only to banks across a much broader range of regulated firms.

This guide helps compliance, HR, and legal leaders understand what's changing, identify governance and process gaps, and build a more defensible approach to culture and conduct oversight.

What you'll learn

This guide walks through the steps firms should take before the new rules take effect.

• Understand how scope, accountability, and reporting are changing for non-bank firms
• Identify where the boundary between workplace and private conduct creates regulatory risk
• Learn why traditional lexicon-based surveillance tools struggle to detect contextual misconduct
• Connect capture, surveillance, HR, and legal workflows into a more defensible compliance process
• Prepare for what FCA examiners expect to see when assessing your culture and conduct program

Why this matters

Non-financial misconduct is becoming a greater regulatory focus across financial services. While these rules apply to FCA-regulated firms, growing enforcement activity in both the U.K. and U.S. signals that culture and conduct are increasingly viewed as enterprise risk.

• Senior managers face personal accountability for misconduct oversight under SM&CR
• Serious non-financial misconduct findings now follow individuals through regulatory references
• The FCA's Sexism in the City inquiry has intensified scrutiny of workplace culture and conduct
• More than $600 million in U.S. culture and conduct settlements underscores the financial consequences of weak misconduct oversight
• Disconnected compliance, HR, and legal workflows can create governance gaps and delay investigations

Build a more defensible approach before the deadline

Firms that wait until enforcement begins will have less time to close governance gaps and less control over how they respond. Download the guide for practical recommendations to strengthen oversight, improve cross-functional workflows, and prepare for the FCA's new requirements before they take effect in September 2026.