Financial Services Compliance — NFM & SMCR Updates
The FCA's Non-Financial Misconduct guidance (COCON 1.1.7FR, PS25/23) comes into force on 1 September 2026. This makes clear that serious bullying, harassment, and sexual misconduct in a work context are no longer just HR matters — they are fitness and propriety issues that can affect whether an individual is considered suitable to hold a regulated role. We have updated 16 existing Financial Services compliance titles and added one brand-new course to ensure your workforce is ready.
FCA deadline: 1 September 2026 COCON 1.1.7FR creates personal regulatory liability for individuals in SMCR firms. Employees, managers, and senior leaders in your organisation need to understand these obligations before the September deadline. Additionally, the FCA's Phase 1 SMCR reforms (PS26/6) came into force in April 2026 — your SMCR training should already reflect these changes. |
New course
Course | What it covers | Key learning outcomes |
Introduction to Non-Financial Misconduct New | Most people in financial services know where the lines are when it comes to money. This course is about a different set of lines — how we treat each other at work, and what happens when those lines get crossed. No prior compliance knowledge assumed. Suitable for all staff in SMCR firms. | – Define NFM and explain why the FCA now treats it as a regulatory issue – Identify behaviours that constitute NFM and the consequences for individuals and firms – Apply speaking-up procedures and know when and how to report concerns |
Updated courses
The following 16 existing courses have been updated to reflect COCON 1.1.7FR, FCA PS26/6 SMCR Phase 1 reforms, and Employment Rights Act 2025 changes where relevant. Your learners who have previously completed these courses may benefit from a re-completion.
Course | Key change |
Bullying and Harassment | NFM added under COCON; ERA 2025 third-party harassment duty |
Sexual Harassment (inc. Worker Protection Act) | NFM recognition under COCON; ERA 2025 employer duty strengthened |
Culture and Ethics | Leadership culture as NFM risk driver; PS25/23 individual accountability |
Equity, Diversity and Inclusion (Financial Services) | ERA 2025 Equality Act amendments; sexual harassment as PIDA qualifying disclosure |
Equity, Diversity and Inclusion (GRC) | ERA 2025 Equality Act amendments; whistleblowing update |
Unconscious Bias | ERA 2025 Equality Act amendments; optional FS note on PS25/23 |
The Conduct Rules | NFM as Conduct Rules breach; worked case study added |
Conduct Risk | NFM threaded through risk identification, management, and MI |
Senior Managers Regime | Full rewrite — PS26/6 Phase 1 reforms; NFM and personal accountability |
Certification Regime | Full rewrite — PS26/6 Phase 1 reforms; NFM fit and proper assessment |
Intro to SMCR | Consumer Duty Champion update; NFM signpost under COCON 1.1.7FR |
SYSC | NFM across fit and proper, SMCR, and Certification; ERA 2025 PIDA update |
Whistleblowing with Confidence | Sexual harassment as PIDA qualifying disclosure; NFM whistleblowing expectation |
Whistleblowing with Confidence for Managers (FS) | FCA PS25/23 NFM expectations; PIDA update for managers |
Understanding Vulnerable Consumers | FCA DPC regulation in force 15 July 2026 (PS26/1) |
Treating Customers Fairly (Non-Retail) | NFM added to SMR and Conduct Rules accordions |