Preparing for the FCA’s Non-Financial Misconduct: What should your firm be prioritising now?

Preparing for the FCA’s Non-Financial Misconduct: What should your firm be prioritising now?

Since the FCA finalised its rules and guidance on non-financial misconduct (NFM) in December 2025, firms have been reviewing policies, governance structures and training programmes ahead of the 1 September 2026 implementation deadline. 

Yet polling conducted during a recent webinar hosted by CCL Academy suggests that only a tiny fraction of firms consider themselves fully prepared. Many are still refining their approach and some remain unclear on what practical steps are required.

While discussion and internal alignment are essential, the focus must now shift from planning to implementation.

The practical questions firms are asking

Following CCL’s various training sessions and webinars across financial services firms, the training provider has responded to a range of queries from firms, with three of the most frequently-asked questions outlined below.

1. Who owns the firm’s response? Under the Senior Managers and Certification Regime, personal accountability is central. Conduct Rule breach reporting, including non-financial misconduct (NFM), must sit clearly within a Senior Manager’s responsibilities.

However, NFM rarely sits neatly within one function. Effective oversight typically requires coordinated input from Compliance, HR and senior leadership. Without clarity around roles, escalation and information-sharing, firms risk delay and inconsistency.

2. What about conduct in an employee’s private life? The FCA makes clear that misconduct in an individual’s private life conduct will generally fall outside the scope of the Conduct Rules, but may be relevant to Fit and Proper assessments. However, the distinction is nuanced and often fact-specific, particularly in areas such as social media activity.

Firms therefore need clear internal guidance that distinguishes between SMF holders, certification staff and other employees, while avoiding mixed messaging that undermines cultural standards.

3. Does everyone need additional training? Many firms already deliver Conduct Rules training. The challenge is deciding whether NFM should be addressed through standalone sessions or integrated into existing programmes.

Because NFM is complex and sensitive, training must be carefully structured. Poorly framed communications can create confusion about expectations, particularly where Conduct Rules and Fit and Proper considerations intersect. The emphasis should be on clarity regarding expectations and examples of real-world application.

Moving from Policy to Practice

As the deadline approaches, regulators will expect more than updated documents. Firms must demonstrate joined-up governance between Compliance and HR, effective escalation frameworks and practical, role-specific training.

Tackling NFM is ultimately about culture, accountability and judgement. Those that prepare early will not only reduce regulatory exposure but also strengthen organisational integrity.

What’s next?

CCL Academy works with firms to translate regulatory change into practical, credible training solutions. If your organisation is preparing for the 1 September 2026 deadline, now is the time to ensure your approach is robust, proportionate and defensible.

Get in touch to discuss how CCL Academy can support your preparations.