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How will the Financial Conduct Authority's non-financial misconduct regime (NFM) impact you and your firm?
Our experts, Sonya Zywko and Claire Holland, discuss the upcoming changes for NFM, including key takeaways from the new COCON and FIT guidance. They also explored what practical steps firms should be taking now to stay ahead. The final guidance was released in December 2025 and will come into effect from September 2026.
The new provisions aim to clarify regulatory expectations in relation to non-financial misconduct, including violence, harassment, bullying and victimisation. They outline when such misconduct is relevant to fit and proper assessments and when it may constitute a breach of the rules, allowing the FCA to take direct enforcement action against individuals.
Culture is intangible but can be underpinned both through the tone from the top and a clear policy framework that clearly identifies conduct which may constitute NFM, whilst remaining flexible to adapt to new circumstances.
Firms need to ensure they have the right policies and procedures in place to encourage employees to report incidents of NFM, ensure a robust investigation takes place and, where appropriate, a subsequent disciplinary process. Senior managers will be under the spotlight in ensuring oversight of implementing the framework, any individual outcomes and regulatory reporting.
Our culture review packages allow you to take a phased approach to tackling compliance and culture within your organisation, enabling you to identify issues and plug gaps so that you can comply with regulatory obligations whilst building a more diverse and inclusive workforce. Find out more here.
Take a look at our videos below, where we explore some of the key questions you may have or watch our recent 'Stay ahead: FCA's non-financial misconduct regime' webinar.
Hear from our experts, Sonya Zywko and Claire Holland, as they examine the new requirements on non-financial misconduct (NFM). Following rule changes in July 2025, the final guidance was released in December and will come into effect from September 2026. This session ensures you’re ready for the new regime shaping the future of diversity, inclusion and accountability in FCA-regulated firms.
Despite a clear expectation from the FCA and Parliament that firms should take a zero-tolerance approach to NFM, but there has been no rules or guidance to follow. The new NFM framework has been devised by the FCA to address this need. Find out more in our video.
There isn’t a single definition. It does capture bullying, harassment and violence but the definition remains broad. Find out more in our video.
It may be relevant. Whilst there is more guidance on what may fall within and outside of scope, grey areas remain. Find out more in our video.
Not every instance of misconduct will be caught, there is guidance on how to determine whether conduct might be caught. Find out more in our video.
Firms can now start looking at the guidance and the procedures and policies they have in place and improvements they can make. Find out more in our video.
For help with a review of your existing NFM framework, see our culture review packages.
If you would like more detail on the issues discussed in these videos, watch our recent webinar here.
