What FCA PS25/23 means for non-financial misconduct

The FCA published Policy Statement PS25/23 in December 2025, confirming its final guidance on how non-financial misconduct fits into the Code of Conduct and the fitness and propriety test. The underlying rule, extending COCON to bullying, harassment and violence between colleagues at non-bank firms, came into force on 1 September 2026.

For banks this formalises a standard they have worked to for years, backed by HR and legal teams built for the purpose. For wealth managers, advisers and other non-banks, this is genuinely new ground. Most have not built the capability banks already have to meet it.

Bullying, harassment and violence now sit inside the conduct rules rather than outside them, so serious misconduct between colleagues can be a conduct rule breach even where it has nothing to do with a client, a trade or a regulated activity. Private life stays largely out of scope, but conduct connected to the performance of someone's role, at a training day, an off-site or a client event, can still fall inside the rules.

What this means in practice.

Most wealth and advisory firms run lean, with a generalist HR function and no in house employment lawyer, because they have never needed one for this purpose. Banks built their capability over years, often after painful, public experience. Wealth firms are now expected to reach a broadly similar standard of judgement and record keeping, at a fraction of the scale and resource, and on a much shorter timeline.

We help wealth managers and advisory firms build a proportionate version of what banks already run, a workable conduct decision framework, manager training pitched at how the business actually operates, and record keeping that would satisfy a supervisor. If PS25/23 affects your firm, get in touch and we can help you close the gap before the FCA's supervisory attention turns to how firms are applying it in practice.