Content updated on May 4 2026
For years, non-financial misconduct in financial services was discussed mostly in qualitative terms: culture, tone from the top, values.
The UK's Financial Conduct Authority (FCA) has now put numbers to it, and they are hard to ignore.
In October 2024, the regulator published the results of its most comprehensive survey to date on how firms record and manage allegations of non-financial misconduct. The survey was sent to 1,028 regulated wholesale firms in February 2024, covering recorded incidents between 2021 and 2023. It was the first comprehensive data-gathering exercise of its kind across these sectors. Combined with the final guidance published in December 2025 and new rules taking effect in September 2026, the direction of travel is clear. This is no longer a soft issue sitting at the edge of compliance. It is a regulatory priority with a deadline.
What the data shows
The number of non-financial misconduct allegations reported by firms increased by more than 70% over the three years surveyed. Bullying and harassment accounted for 26% of recorded incidents, discrimination for 23%, and 41% fell into an "other" category covering conduct including alcohol misuse in the workplace, inappropriate communications, retaliation against colleagues who had reported concerns, and expense policy violations.
Grievances and similar formal escalation processes were the most common detection method. Whistleblowing channels identified 16% of all reported incidents, but the picture varied sharply by sector. Only 6% of incidents at wholesale intermediaries came through whistleblowing channels, compared to 32% at wholesale banks.
It was rare for allegations not to be investigated: only 1% of complaints were left uninvestigated. But 35% of allegations were not upheld after investigation. For bullying and harassment specifically, 47% were not upheld. For discrimination, 62% were not upheld.
The FCA was careful to note that higher reporting volumes do not automatically indicate a poor culture. A high number of complaints can in fact be a sign of a healthier speak-up culture. The absence of reports is not the same as the absence of misconduct.
The regulatory response
The survey did not sit in isolation. It is part of a sustained programme of regulatory action building since the Treasury Committee's Sexism in the City report in March 2024, which described levels of sexual harassment in the industry as "shocking."
In December 2025, the FCA published Policy Statement PS25/23, containing its final guidance on non-financial misconduct. The guidance comes into force on 1 September 2026. It does two things. It amends the Code of Conduct sourcebook to explain how non-financial misconduct can constitute a breach of the conduct rules, and clarifies how it forms part of the Fit and Proper test for employees and senior personnel.
The scope of who this applies to is also expanding. From 1 September 2026, the FCA will extend its conduct rules to make clear that serious misconduct such as bullying, harassment and violence is a matter of regulatory concern at all SMCR firms, not just banks, bringing equivalent expectations to around 37,000 firms.
The FCA has also been explicit that where these behaviours go unchallenged, it will treat this as a red flag indicator of cultural failings that can undermine decision-making and risk management. Senior managers may be held responsible for bad behaviour anywhere in their ranks, not just their own conduct.
The supervisory data reflects this. Open supervisory cases tagged as relating to non-financial misconduct rose from 123 in 2022 to 168 in 2023, 229 in 2024, and 176 in the first nine months of 2025 alone.
Where whistleblowing fits in
The gap between 6% and 32% whistleblowing reporting rates across sectors is not just a statistical curiosity. It points to real structural differences in how seriously firms have invested in making their reporting channels trusted, accessible and visible to employees.
The survey found that not all firms had an up-to-date whistleblowing policy in force, and a significant proportion of larger firms had no formal governance structure for deciding outcomes when allegations were substantiated.
The FCA has been direct about its expectations. It has updated its own website to make it easier for external whistleblowers to report concerns, and clarified that reports can be made even where confidentiality or non-disclosure agreements are in place. Firms are expected to meet the same standard internally.
A whistleblowing policy on paper is not the same as a whistleblowing system that works. The gap between the two shows up in reporting rates, in the proportion of concerns that never reach a formal channel, and in the incidents that escalate into regulatory or reputational problems because they were not caught early.
What firms need to do before September 2026
The FCA has stated it will now focus on how firms are tackling non-financial misconduct in practice, not just in policy. For firms that have not yet reviewed their systems, the timeline is tight.
At a minimum, firms should assess whether their whistleblowing infrastructure is genuinely trusted, not just technically compliant. The sector gap in reporting rates is a useful starting point: if your firm is closer to 6% than 32%, that gap is worth understanding. Firms should also check whether non-financial misconduct is being discussed at board and senior management level, and whether investigation processes and audit trails are documented well enough to withstand regulatory scrutiny.
The primary responsibility for preventing and dealing with non-financial misconduct lies with firms. The FCA's new rules are designed to drive higher and clearer standards across the industry from 1 September 2026.
Conclusion
The FCA's figures are a wake-up call for the industry. A 70% increase in reported incidents shows that the culture is starting to shift, but the massive gap between sectors is the real story. If only 6% of a team is using official channels to speak up, it is usually a sign that they simply do not trust the process.
The September 2026 deadline is not just another date for your compliance calendar. It is when the regulator will start judging firms on their actual impact rather than just their intent.
Whispli was built to solve this exact trust problem. We help you move past paper policies by giving your employees a channel they are actually comfortable using. Bridging the gap from 6% to 32% requires more than just new rules: it requires a platform that works in the real world.
With Whispli's whistleblowing and case management platform, you can deal with misconduct while it is still an internal issue, keeping it off the regulator's radar and protecting your company’s reputation.
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