Drawing a line | What the FCA's new Code of Conduct update means for HR leaders

New rules and guidance to help tackle non-financial misconduct (NFM) came into effect on 1 September 2026 under the Financial Conduct Authority (FCA). 

The rule itself - COCON 1.17FR - is a minor update, but one which carries potentially major consequences. 

Functionally it extends the FCA’S Code of Conduct to serious NFM - bullying, harassment, including sexual harassment, and violence – where there is a sufficient connection to an individual employee and their role. 

In practice this means any findings of NFM can now bear on an individual's fitness and propriety, must be captured in regulatory references when someone moves between Senior Managers and Certification Regime (SM&CR) firms, and can put a senior manager in front of the FCA for how they responded, not just the actions taken in any given case.