TLT

On 2 July 2025, the FCA launched a consultation on draft guidance aimed at supporting firms dealing with non-financial misconduct (NFM). It also published a Policy Statement confirming final rules in the Code of Conduct sourcebook (COCON) that extend existing NFM rules to non-banks.

This article considers the changes, the proposed draft guidance and what firms should do now. 

By David Hamilton, Partner (Howard Kennedy LLP)

The Financial Conduct Authority (FCA) has entered a new era of enforcement; one defined by speed, strategic focus, and a recalibrated approach to transparency. That's the plan, anyway.

The regulator’s revised Enforcement Guide (ENFG), published in June 2025 as part of Policy Statement PS25/5, marks the most significant overhaul of its enforcement framework since 2007. For firms, this is not merely a procedural update; it is a signal of deeper regulatory intent, with practical implications for governance, culture, and risk management.