On 2 July 2025, the FCA published its long-awaited approach to non-financial misconduct (NFM). This includes a Policy Statement amending the Code of Conduct (COCON) to explicitly bring serious personal misconduct into scope, and a consultation on new guidance for both COCON and the Fit and Proper Test for Employees and Senior Personnel (FIT).

The FCA’s aim is clear: to raise standards, increase accountability, and build public trust in financial services after some recent high-profile controversies in respect of senior finance professionals. 

In this article, Rachel Cook and Liam Lane discuss the FCA’s new approach, dissecting what constitutes as non-financial misconduct and what lies ahead following the update. 

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