FCA non-financial misconduct rules: PIMFA issues firm playbook

UK wealth managers and advisers now have a practical playbook for the FCA's non-financial misconduct rules, which take effect on 1 September 2026. PIMFA, the trade body for UK wealth managers and financial advisers, published guidance on 23 June 2026 developed with the Chartered Insurance Institute, the Chartered Institute for Securities & Investment and law firm Clyde & Co. The document translates principles-based regulation into worked scenarios, a fitness-and-propriety framework and an implementation checklist, arriving roughly ten weeks before compliance becomes mandatory.

What actually changes on 1 September 2026?

From that date, the FCA's updated Code of Conduct rule at COCON 1.1.7FR extends to the roughly 37,000 non-bank firms already inside the Senior Managers and Certification Regime. Serious bullying, harassment and violence toward colleagues become capable of constituting conduct rule breaches, and disciplinary action tied to such breaches is reportable to the regulator. The rules are not retrospective and will not require firms to revisit prior conduct assessments.

Crucially, the FCA built guidance rather than a prescriptive checklist. The regulator's final policy statement followed a consultation in which 95% of respondents requested additional support, reflecting how much interpretive uncertainty firms faced. PIMFA's guidance fills that gap by mapping where judgement is required.

Where do the hardest judgement calls sit?

The guidance targets the grey zones. It addresses the boundary between work and private life, the relevance of social media activity, and how the FCA's framework interacts with obligations under the Equality Act 2010. Clyde & Co has previously flagged that conduct at client events, training days, work-related travel and industry functions can fall within scope where there is a sufficiently close connection to the workplace, the precise terrain firms find hardest to police.

To operationalise this, the guide includes worked scenarios spanning social media posts, after-work events and allegations involving senior staff, alongside a checklist of actions and a framework for assessing fitness and propriety.

Why is the regulator pushing this now?

The data behind the rule change is stark. An FCA survey of 1,028 wholesale firms, published in October 2024, found reported non-financial misconduct incidents rose 72% between 2021 and 2023, climbing from 1,363 cases to 2,347, a total of 5,380 incidents over the period. Bullying and harassment accounted for 26% of recorded concerns and discrimination 23%, while disciplinary or other action was taken in only 43% of cases. Regulatory references mentioning misconduct rose from 16 in 2021 to 43 in 2023, a 169% increase, signalling that firms are beginning to track these issues through hiring.

The FCA has been explicit that its policy work is now complete and its attention has shifted to enforcement in practice, placing the burden of cultural change on firms themselves.

Why This Matters to FinanceX Readers

For wealth and advice firms, 1 September 2026 converts workplace culture from an HR concern into a regulatory one with reporting consequences and fitness-and-propriety implications for individuals. With disciplinary action historically taken in fewer than half of recorded cases, the FCA's enforcement-first posture means firms with weak detection, governance or escalation processes are now exposed. The commercial stakes extend beyond compliance: a 169% rise in misconduct-flagged regulatory references shows poor conduct increasingly follows individuals between firms, reshaping hiring diligence across the sector.