FCA’s new non-financial misconduct regime: Caroline Black comments in Law360

The Financial Conduct Authority’s new non-financial misconduct rules come into effect on 1 September 2026, extending existing conduct standards to around 37,000 non-bank financial firms, including asset managers and insurers. The rules cover bullying, harassment and violence at work, while separate fitness and propriety guidance may also make certain conduct outside the workplace relevant.

In a recent Law360 article examining the potential impact of the new regime, Caroline Black, Consultant at Gherson Solicitors LLP, highlighted the importance of firms recognising where HR matters may now give rise to regulatory obligations.

Caroline commented:

“What was previously viewed as purely an HR matter now will fall within the [non-financial misconduct] reporting obligations … Recognition and alignment are key”.

The changes mean regulated firms will need to ensure that HR, compliance and management teams are aligned and able to identify when workplace conduct may also create regulatory and reporting requirements.

The Law360 article also highlights concerns around regulatory references and the potentially significant consequences that adverse findings could have for individuals seeking roles elsewhere in the financial sector.

Read more in the Law360 article: “FCA Non-Financial Misconduct Regime Will Endanger Careers.”