About
AIMA has partnered with Travers Smith to provide practical guidance for AIMA members on the UK Financial Conduct Authority’s (FCA) new non-financial misconduct rule and guidance, which will take effect on 1 September 2026.
The changes, set out in the FCA’s Policy Statement 25/23 (published in December 2025), provide clarification on how non-financial misconduct should be considered within the UK's Senior Managers and Certification Regime (SM&CR). The new rule extends the scope of the Conduct Rules for non-bank SM&CR firms and the FCA has issued guidance on when "serious" non-financial misconduct, such as bullying, harassment and violence, may have regulatory implications. The FCA's guidance also clarifies when conduct that takes place in a person's private or personal life, including on social media, may be relevant to an assessment of an individual's fitness and propriety.
We have published this guide to help firms navigate the FCA's new requirements and outline key actions firms should consider ahead of go-live.
Structure
The Guide is structured as follows:
Section 1 – Overview of the New FCA Rule and Guidance
Section 2 – What Conduct Constitutes NFM under the New Rule and Guidance
Section 3 – NFM and the Conduct Rules
Section 4 – NFM and Fitness and Propriety
Section 5 – Additional Considerations
Section 6 - Case Study
Download the Guide
For more information please contact Aniqah Rao, Associate Director, Markets, Governance and Innovation, AIMA.