The FCA has published a new webpage to help firms apply COCON and FIT in preparation for the new non-financial misconduct rules which come into effect on 1 September 2026. This highlights new Handbook guidance (PS25/23) aimed to assist firms in applying the new rules, first published in December (see further here).
The FCA is encouraging firms to use the run-up to September to consider whether they need to update their approach to:
- Staff policies.
- Conduct breach reporting.
- Fit and proper assessments.
- Regulatory references.
Firms should also ensure staff and managers understand how the changes apply to them.
The FCA also clarifies that firms do not need to:
- Carry out retrospective analysis to check whether they correctly determined past conduct rule breaches.
- Revise past fitness and propriety assessments.
- Monitor employees’ private lives or social media accounts.
- Investigate allegations about employees’ private lives if they are trivial, implausible or irrelevant.
- Do anything contrary to privacy, employment or other relevant law.
These points were raised by a number of consultation respondents and further clarification here is welcome.

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