As the 1 September 2026 implementation date draws near, UK finance firms have accelerated work on internal systems to absorb the Financial Conduct Authority's updated rules on non-financial misconduct.
The policy statement PS25/23, released on 12 December 2025, sets out how serious instances of bullying, harassment or violence against colleagues will be treated where a sufficient work-related link exists. A new provision in the Code of Conduct sourcebook, COCON 1.1.7FR, extends these standards to roughly 37,000 additional non-bank Senior Managers and Certification Regime firms.
The FCA has been clear on the boundaries. "The new rule will apply where there is a sufficient work-related link. It will not apply retrospectively or extend our regulatory remit beyond Senior Managers and Certification Regime (SM&CR) financial activities," the regulator stated. Nor will firms be expected to monitor private lives or social media, or to revisit past fitness and propriety decisions.
Legal and advisory firms have counselled clients to review staff policies, conduct breach reporting, fit and proper assessments and regulatory references. The guidance also clarifies how non-financial misconduct, whether in work or in private life when relevant, should inform those assessments under the FIT sourcebook.
Firms are focusing on practical steps: refreshing training so staff and managers understand the changes, stress-testing existing processes, and aligning HR, compliance and legal teams. The aim is to ensure consistent decision-making ahead of what will become heightened supervisory attention.
