Nonfinancial misconduct is no longer just a people issue. It is a regulatory issue. Poor behaviour such as bullying, harassment or violence can now pose a material risk to a firm. From 1 September 2026, the FCA’s extended rules apply to all SMCR firms, not only banks.
This change matters because non‑financial misconduct can create real risk. The FCA expects firms to manage it with the same seriousness as financial misconduct. The updated Conduct Rules and Fit and Proper standards require stronger evidence, clearer judgements and better oversight. These sit alongside new duties in employment law and whistleblowing rules taking effect through 2026.
This is difficult work and presents a practical challenge for firms. Non‑financial misconduct is hard to define, evidence and escalate. Boundaries with private life can be complex, and social‑media activity can still be relevant.
What pressures are different parts of the sector facing?
Different parts of the sector face different pressure points:
- insurers need consistent, market‑wide approaches
- investment banks need stronger governance over interpersonal conduct
- retail banks need better training for frontline managers
- asset and wealth managers must formalise culture and conduct processes. These may have handled informally in the past
Across the board, the expectation is clear: firms must show they identify issues early, escalate them properly and act with sound judgement.
What is the FCA focusing on?
So what is the FCA looking for? The FCA will focus on outcomes, not just processes. It will ask whether your handling of a serious case strengthens rather than weakens your SM&CR position, and whether you can support decisions with evidence rather than policy statements alone.
At Grant Thornton, we help firms build frameworks that stand up to regulatory scrutiny. That includes helping firms:
- set clear definitions with defensible standards
- strengthen governance, oversight and escalation routes
- manage sensitive and strategic non financial misconduct risks, such as exits and disputes
Non‑financial misconduct rules demand confidence and competence. We help firms build both. If you would like support preparing for the new rules or testing your readiness, we would be happy to help.