The UK's Financial Conduct Authority will enforce expanded non-financial misconduct rules on Sept. 1, pulling every firm regulated under the Senior Managers and Certification Regime (SMCR) into a workplace-conduct regime previously limited to banks.

Non-bank financial services firms must now prevent bullying, harassment and violence among colleagues when the conduct is related to work, even where the activity sits outside regulated business lines. The FCA set out the handbook mechanics in policy statement PS25/23, released ahead of the September implementation date.

What's actually changing on Sept. 1?

The original SMCR misconduct rules applied to banks. PS25/23 removes that carve-out, so any non-bank SMCR-regulated firm now sits in the same regulatory perimeter as a high-street bank on workplace bullying and harassment. The duty covers conduct "related to work" — language designed to capture off-site behaviour, after-hours interactions and conduct not directly tied to a regulated activity.

Squire Patton Boggs, the law firm that published an analysis of the package, called the moment one where "regulatory and employment law obligations increasingly converging."

What's running alongside the NFM rules?

The FCA's deadline lands inside a wider UK employment-law reset. HR teams that draft once-a-year policy reviews are now juggling a four-track legislative timetable. According to the same analysis, the concurrent changes include:

• A prohibition on certain non-disclosure agreement (NDA) provisions that silence workplace harassment claims
• New whistleblowing protection for sexual harassment disclosures
• A strengthened statutory duty to prevent sexual harassment
• Changes to employment tribunal time limits and unfair dismissal rights

The overlap matters because a single workplace harassment incident can now trigger an FCA supervisory response, an employment tribunal claim and a protected whistleblower disclosure through three separate statutory routes. Each carries its own definitions, evidence rules and disclosure triggers.

What should HR do before September?

Squire Patton Boggs recommends firms review four operational areas: policies, training, investigation processes and governance arrangements. Each must be "fit for purpose" ahead of the implementation date, the firm said.

For HR leaders, the practical test is whether existing grievance processes can feed the FCA's information requests. An internal investigation that resolves a bullying complaint without notification could now count as a regulatory gap rather than a closed HR file.

Senior managers already carry SMCR accountability for conduct risk under the existing regime. The expansion extends that line of sight further down the org chart, into behaviour that until September sat outside the FCA's perimeter entirely.

What does this mean in practice?

The shift reframes misconduct prevention as a regulatory deliverable, not just an employment-policy task. Bullying and harassment — long the domain of grievance procedures and tribunal claims — now sit on the same shelf as capital adequacy and client money safeguards in the FCA's handbook.

That carries consequences for document retention, training records and disciplinary outcomes, all of which the FCA can request during a supervisory review. HR functions that haven't kept granular records on training completion or complaint resolution may need to rebuild those records before September.

Firms with lean HR resourcing face an additional calculation. A workplace complaint now travels through internal grievance, FCA notification and possible tribunal filing, and HR sits at the junction of each pipeline.

What's the practical HR programme?

The FCA's handbook guidance gives firms a runway, but not a long one. PS25/23 sets out the regulator's view on what counts as misconduct, how firms should investigate and what records supervisors expect to see.

For HR, the work programme runs to four items: align handbook policies with the expanded definition of work-related conduct, refresh training modules, test investigation scripts against FCA disclosure standards and brief senior managers on their new accountability lines.

The September deadline leaves firms under four months to align employment policy with the new supervisory overlay — and PS25/23, the FCA's published handbook guidance, sits on the regulator's website waiting to be read.