Building a Non-Financial Misconduct Framework for FCA Authorised Firms

Introduction

The FCA's new rules on non-financial misconduct (NFM) come into force on 1 September 2026. PS25/23 introduces guidance on how NFM can breach the Conduct Rules and how it should be factored into Fitness and Propriety assessments. Firms need frameworks in place before the deadline.

This live and interactive session provides a practical, step-by-step approach to building an NFM framework that works within your existing structures and resources. You will leave with a clear understanding of what needs to be in place, how to integrate NFM into your current HR and compliance processes, and how to evidence your approach if the FCA asks.

This virtual classroom seminar also addresses common challenges including defining what conduct falls within scope, managing GDPR constraints, and adapting governance arrangements without creating unnecessary bureaucracy.

What You Will Learn

This live and interactive session will cover the following:

• Brief background:
• The FCA's journey from 2021
• What the new COCON guidance requires and how it applies to your firm
• How non-financial misconduct feeds into the Fit and Proper assessment and your certification process
• Building your NFM Framework:
• The essential components of your NFM framework
• Defining what conduct falls within scope
• Integrating NFM into your existing HR and compliance processes
• GDPR considerations
• Governance and Oversight:
• Adapting your existing governance structure
• The expanded role of line managers in early intervention
• Preparing for September 2026:
• A realistic implementation timeline for firms starting now
• How to evidence your framework to the FCA if asked

Recording of live sessions: Soon after the Learn Live session has taken place you will be able to go back and access the recording - should you wish to revisit the material discussed.