Ropes & Gray Hosts Roundtable on the FCA's Non-Financial Misconduct Rules

On April 22, Ropes & Gray hosted a roundtable in London on the FCA's forthcoming Non-Financial Misconduct rules, which come into force on September 1, 2026. The session was led by co-head of the anti-corruption and international risk and crisis management & investigations practices Amanda Raad, asset management partner Eve Ellis, and director of behavioral insights Nitish Upadhyaya.

The new rules embed non-financial misconduct—covering bullying, harassment, and violence—into the FCA's individual conduct rules, affecting both individuals' behavior and managers' accountability. Firms must also now consider such misconduct when assessing fitness and propriety of certified staff. Both changes will have knock-on effects for reporting obligations and regulatory references. The FCA expects firms to treat this as a regulatory conduct matter, not just a human resources issue.

The roundtable explored how these rules work in practice through the lens of questions that clients are asking and the practical steps firms should take now—including updating governance processes, revising conduct frameworks and policies and procedures, updating fitness and propriety assessments, mapping existing data sources which can be used to detect non-financial misconduct, and ensuring staff and managers understand how the changes apply to them. The roundtable also considered the broader question of how to embed speak up and reporting within organizational culture.

To prepare, listen to our podcast mini-series on the regulatory framework. A catch-up webinar is scheduled for 30 April (10am EDT / 3pm BST) for those who could not make the roundtable, and a recording will be available after the session. To express an interest in attending the live webinar or receiving the recording, and for more materials, contact any of the speakers listed below.