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Thursday, July 16, 2026

The FCA’s new rules on non-financial misconduct: whistleblowing and the rising burden on managers - Burges Salmon

This is our fourth article in our series on the FCA’s new rules on non-financial misconduct, which come into force on 1 September 2026. Our series focuses on key issues for HR professionals and other individuals with responsibility for people issues in regulated financial services firms.

In this article, we look at the role of managers in the new regulatory framework, particularly in the context of speak up and whistleblowing channels.

The FCA’s new rules and guidance on non‑financial misconduct come into force on 1 September 2026. Internal reporting and escalation channels will play an increasingly critical role in identifying and addressing non-financial misconduct within the workplace and in work-associated environments.

The role of managers in tone-setting and culture

The FCA guidance sets the bar high for managers’ diligence in spotting, intervening, preventing and reporting non-financial misconduct (such as bullying, harassment and other forms of inappropriate conduct) in the workplace and in work-associated environments. In this context, ‘managers’ includes both Senior Managers holding Senior Management Functions within FCA-regulated firms and also small ‘m’ managers who are subject to the Conduct Rules.

There is additional jeopardy for managers because they are at risk of personal breach of the Conduct Rules for failing to take steps to prevent non-financial misconduct that falls within the rules' regulatory reach.

What does this mean for managers?

The FCA...



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