NON-FINANCIAL
MISCONDUCT
From 1 September 2026, how your staff treat each other is a regulatory matter. Not a policy aspiration. A rule.
A conceptual shift,
not a technical one.
Policy Statement PS25/23, published 12 December 2025, finalised a new rule in the Code of Conduct sourcebook numbered COCON 1.1.7FR. It applies to approximately 37,000 non-bank Part 4A-authorised firms.
Until now, the implicit theory was that how colleagues treated one another was an HR matter — serious where it went wrong, but not regulatory. That theory is dead.
The same incident can now trigger an employment tribunal claim, a disciplinary proceeding, a Fit and Proper reassessment, a Statement of Responsibilities review, an enforcement investigation, and — in the most serious cases — a prohibition order.
“Complexity creates risk.
Simplicity creates protection.— Chapter 1, The Big Why
Four distinct ways
a career ends.
The new rule exposes Senior Managers along four separately consequential vectors. Each is individually career-defining. Combined, they are catastrophic.
Fine, public censure, prohibition
Loss of SMF approval
Damages, injunctions
Loss of future roles, D&O repricing
Five steps you can recall
under pressure.
If the FCA called
tomorrow—
could you prove it?
Get the 170-Page playbook before 1 September 2026.
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