On 2 July 2025, the FCA finally issued its long-awaited next steps document (CP25/18: Tackling non-financial misconduct in financial services) on the proposed new guidance on non-financial misconduct (NFM).
The document contains two key elements:
Rule Change from 1 September 2026 – The FCA will extend its Code of Conduct Rules (COCON) to non-bank firms, following strong support from its consultation (CP23/20). This change aims to address ambiguity around conduct breaches (e.g., serious bullying or harassment) in non-banks and will bring about 37,000 additional regulated firms into scope. However, entities without a Part 4A permission (e.g., payment firms, e-money institutions, investment exchanges, and credit rating agencies) will remain outside the scope.
Consultation Open Until 10 September 2025 – The FCA is consulting on new guidance in its Handbook to help SMCR firms better understand and apply conduct rules and fitness/propriety standards. Feedback is sought by 10 September 2025, with final guidance expected by year-end.
Key Takeaways
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