Non-Financial Misconduct: What Small Firms Need To Do

Which small firms are affected?

For the full regulatory background, the consultation history, and the FCA's policy statement analysis, see Skillcast's non-financial misconduct guides. This hub covers what small firms need to do and how to evidence it. Skillcast.com covers the regulation itself.

In scope from 1 September 2026

• IFAs and financial advice firms
• Investment and wealth managers
• Insurance and mortgage brokers
• Payments and e-money firms
• Consumer credit firms
• Every other non-bank SM&CR firm, regardless of size

What the FCA expects you to have

• Conduct Rules training updated to cover non-financial misconduct
• A clear bullying and harassment policy staff can find
• Senior managers briefed on their responsibilities
• Fitness and propriety assessments that consider NFM
• Records showing all of the above happened

The training and the audit trail, in one subscription

The NFM courses

CPD-certified training on the new rules, built for SM&CR firms and included in every subscription. Assign it to your whole team in minutes, refreshers repeat automatically.

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Audit-ready records

Every completion is timestamped and downloadable. If the FCA, a skilled person, or an employment tribunal asks what training your firm ran on non-financial misconduct, the answer is one click away.

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Aida on standby

When a specific situation comes up, ask Aida, your AI compliance assistant. Grounded in verified regulatory sources, cites the FCA Handbook, and refuses what it does not know. Included on every plan.

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Your questions, answered

Non-Financial Misconduct

Non-Financial Misconduct

Does this (NFM) apply to my firm if we only have five staff?

Yes. The rules apply to all SM&CR firms from 1 September 2026, with no size threshold. The FCA's expectation of proportionality affects how you implement, not whether you do.

What counts as non-financial misconduct under the rules?

Serious bullying, harassment (including sexual harassment), and violence toward colleagues. The FCA has been clear the bar is serious misconduct, not everyday workplace disagreement, and that conduct can be relevant to fitness and propriety even where it happens outside work in some circumstances.

Do we need a separate NFM policy?

Not necessarily separate, but you need a clear, findable bullying and harassment policy that reflects the new rules, and evidence that staff have seen it. Many small firms fold NFM into an updated conduct policy.

We already did Worker Protection Act training. Does that cover this?

It helps but it is not the same thing. The Worker Protection Act duty covers preventing sexual harassment as an employer. The FCA's NFM rules sit in the Conduct Rules and affect regulatory obligations, fitness and propriety, and references. You need training that covers the regulatory dimension too.

What happens if we do nothing?

The rules apply either way. The practical risk is being unable to show the FCA, an employment tribunal, or a regulatory reference request that your firm trained staff and had a policy in place. Firms are rarely sanctioned for a single incident alone; they are criticised for having no evidence they took the obligation seriously.

Is the NFM training included or an add-on?

Included. The NFM course and the evidence reporting are part of the standard CoreCompliance subscription at no additional cost.

Is there still time to be ready before 1 September?

Yes. For a firm under 50 staff, the core work is updating the policy, assigning training, and briefing senior managers, which is realistically a few weeks of elapsed time, not months. The checklist above sequences it.