FSR Brief EP8: Non-Financial Misconduct – more questions raised than answered?

On 2 July 2025, the FCA published Consultation Paper 25/18 https://www.fca.org.uk/publication/consultation/cp25-18.pdf, "Tackling non-financial misconduct in financial services", comprising both a Policy Statement and final rules, together with further consultation on the revised guidance proposed for the FCA Handbook. It has taken the FCA considerable time to reach this phase in the development of its NFM policy, and there has been significant change from its original proposals in CP23/20 https://www.fca.org.uk/publication/consultation/cp23-20.pdf. Even with further clarity and guidance from the FCA, this undoubtedly remains one of the most difficult areas for firms to grapple with. Join Jon Ford, Hywel Jenkins, Christine Young and Michael Tan as they discuss CP25/18 and consider whether it raises more questions than it answers.