The September 2026 Deadline Is Coming. Is Your Firm Ready for the FCA’s Non-Financial Misconduct Rules? Non-Financial Misconduct is no longer a workplace issue that sits quietly with HR. As of 1 September 2026, it becomes a regulatory one.
The FCA’s Policy Statement PS25/23, published in December 2025, confirmed what the industry had been anticipating for years. Bullying, harassment, and violence in financial services will be treated as conduct rule breaches under the new COCON 1.1.7FR rule. The scope now extends beyond banks to approximately 37,000 non-bank firms, including insurers, hedge funds, and pension companies (FCA, PS25/23).
The implications run deeper than a single rule change. Fitness and propriety assessments now explicitly incorporate non-financial misconduct. Senior managers who knew about misconduct and failed to intervene can be found in breach of the due skill, care, and diligence conduct rule under COCON 2.1.2R. Regulatory references must disclose serious, substantiated personal misconduct, closing the loophole that allowed individuals to move between firms undetected (DLA Piper, 2025).
This is not a narrow compliance exercise. The FCA has made clear that it views unhealthy workplace culture as a leading indicator of broader organisational risk. Firms that tolerate toxic behaviour are, in the regulator’s view, firms that are likely to produce poor outcomes for consumers and markets alike.
Most firms will respond to the new rules with updated policies, revised training modules, and a refreshed whistleblowing procedure. These are necessary steps. They are not sufficient ones.
The FCA’s own survey data found that 50% of firms only identified non-financial misconduct incidents through formal grievance or whistleblowing channels (FCA, 2024). That means the other half went undetected through existing processes. More concerning still, only 43% of reported cases resulted in disciplinary action or another meaningful outcome. These numbers tell us something important. The formal machinery of compliance is not working well enough on its own.
Policies tell people what they should not do. Culture determines what they actually do. When a decision is ambiguous, time-pressured, and high-stakes, employees do not consult the handbook. They look at what the people around them are doing, particularly the people with power and influence. If those leaders model the wrong behaviours, no amount of training will compensate.
This is where the conversation needs to shift. The firms that will be best positioned for the FCA’s post-September 2026 supervisory focus are not the ones with the thickest policy documents. They are the ones that can demonstrate, with objective evidence, that they are actively measuring, managing, and improving the behaviours that prevent misconduct before it happens.
That requires moving beyond surveys and self-assessments to evidence-based approaches grounded in real workplace data. It requires giving leaders the tools to see their own communication patterns and understand how those patterns shape the culture around them. And it requires doing this collaboratively, not in isolation, because the challenge of defining what good conduct looks like is one that no single firm can solve alone.
The Leadership Programme, developed by FinTech-Tables in partnership with SolasOS, was designed for exactly this moment. It brings together 5 to 8 financial services organisations in a structured, evidence-based programme that moves from individual organisational insight to collective industry leadership on non-financial misconduct.
The programme uses SolasLite communication analytics to give leaders a data-grounded view of their own behaviours, not based on surveys or perception, but on what actually happens in day-to-day communication. Participating organisations define their own behavioural frameworks, then come together in a collaborative hackathon to develop shared industry standards. The output is a cross-industry research report and an ongoing community of practice.
The September 2026 deadline is a starting point, not a finish line. The FCA has stated that its policy work on NFM is now complete and it will shift to supervising how firms tackle it in practice (Linklaters, 2025). The organisations that move first, that define the standards and build the evidence, will shape the regulatory conversation for years to come.
The question is not whether your firm needs to act. It is whether you want to lead or follow.
Ready to act?
Applications are now being accepted for the Non-Financial Misconduct Leadership Programme from FinTech-Tables and SolasOS, designed for financial services organisations preparing for the next phase of regulatory change.
To learn more, visit https://fintech-tables.com/events/non-financial-misconduct-leadership-programme/
I specialise in bringing about change and behaviourally-led growth at organisation, team and individual level.
After 13 years in FS at what is now Aviva, I emerged as an ACII, MBA and senior manager from its multiple mergers. I was determined to apply my learning from these transformative changes to help people and organisations grow through disruption.
24 years later, my work in that has taken me to 15 countries across multiple sectors, including Financial Services.
My businesses in Leadership (Actif4) and Change (Initiate) challenge people and organisations to be future-focused, spiced with applied learning from the past.
With SolasOS, alongside Iain Hamilton, the next stage of development is underway — applying next-gen technology in providing deep insight on very human challenges — all to help people and their organisations to grow and bring about successful change.
It is great to see the Financial Services embracing the FinTech sector, and I am excited by the potential that we bring with Solas-OS to broaden the FinTech impact more fully across Financial Services’ people and cultures.
