FCA compliance is undergoing a significant reset. During 2026, firms have already had to respond to changes affecting the Senior Managers and Certification Regime, safeguarding requirements and regulatory reporting. From 1 September, the FCA’s expanded approach to non-financial misconduct will bring workplace behaviour more firmly within the regulatory framework.
Further reform is approaching. The government plans deeper changes to SMCR through the Enhancing Financial Services Bill announced in May. This will see the introduction of deeper Phase 2 reforms to SMCR. Meanwhile the FCA is reconsidering parts of the financial promotions regime and a comprehensive regulatory framework for cryptoassets is taking shape.
Employees and senior managers of FCA-regulated firms must be able to apply the rules to realistic decisions. VinciWorks has rebuilt its FCA training suite to reflect this changing environment. New courses address emerging risks, existing courses have been reviewed and updated, and further releases are being developed around the issues compliance teams will need to manage next.
Non-financial misconduct enters the Conduct Rules
The most immediate training deadline is 1 September 2026, when the FCA’s new non-financial misconduct rule and final guidance come into force.
COCON 1.1.7FR will extend the Conduct Rules in non-bank firms to cover serious bullying, harassment and violence against colleagues where there is a sufficient connection to the individual’s role. The associated guidance also explains how non-financial misconduct can affect fitness and propriety assessments. It applies to FSMA firms with a Part 4A permission and the individuals within those firms who are subject to COCON or FIT.
This does not mean every objectionable action in someone’s private life becomes an FCA matter. Firms will need to understand concepts such as the work-related link, material regulatory risk, integrity, proportionality and the quality of the available evidence. Managers must know when an allegation should be escalated and when a regulatory investigation would be disproportionate.
VinciWorks has introduced two new courses to help firms prepare:
FCA Non-Financial Misconduct: Navigating the COCON Rules
This course explains how bullying, harassment, violence and other serious misconduct can affect the Conduct Rules, workplace culture and fitness and propriety. It helps learners understand when conduct becomes relevant to the FCA, how material risk should be assessed and why proportionate escalation matters.
FCA Code of Conduct: Upholding the FCA’s Standards
The updated COCON course provides a broader grounding in the FCA Conduct Rules. It connects everyday decisions, workplace behaviour, individual accountability and leadership conduct to customer outcomes and regulatory expectations.
Together, the courses allow firms to deliver focused training on the new misconduct framework alongside wider Conduct Rules training for employees and managers.
SMCR reform is already under way
The first phase of SMCR reform took effect across several dates in 2026. Most changes applied from 24 April, further reporting and process changes took effect on 10 July, and changes removing overlapping certification functions from the FCA Directory are due to apply from 30 July. Alignment with the non-financial misconduct framework follows on 1 September.
The Phase 1 reforms affect areas including criminal record checks, the 12-week rule, Statements of Responsibilities, management responsibility maps, regulatory references, certification functions, enhanced firm thresholds and Conduct Rules reporting. Our earlier analysis provides more detail on how these changes affect firms’ operational processes.
Deeper reform is also approaching. The Enhancing Financial Services Bill was announced to Parliament in the May 2026 King’s Speech.
The government’s SMCR reform package would:
- Remove the Certification Regime and annual recertification requirement from primary legislation, allowing the FCA and PRA to develop a more flexible framework through their rulebooks.
- Reduce the number of Senior Management Functions requiring regulatory pre-approval, with some appointments potentially relying on firms’ own fitness and propriety assessments followed by notification.
- Remove prescriptive statutory provisions governing Statements of Responsibilities and aspects of the Conduct Rules framework.
- Give the regulators greater flexibility to set proportionate requirements through rules and guidance.
This could reduce repetitive administration. It will also increase the importance of sound internal decisions. Firms may need stronger evidence supporting role classifications, fitness and propriety assessments, responsibility allocations, regulatory references and decisions about whether conduct should be reported.
The refreshed VinciWorks course on SMCR: The Senior Managers and Certification Regime reflects the Phase 1 changes and the direction of the wider reforms. It helps learners understand how individual accountability operates even as the surrounding processes evolve.
Safeguarding requirements have changed for payments and e-money firms
The FCA’s Supplementary Safeguarding Regime came into force on 7 May 2026. It strengthens record-keeping, reporting and monitoring requirements for payment and e-money firms and is intended to reduce shortfalls in safeguarded funds when a firm fails.
The changes apply to authorised payment institutions within scope, authorised and small e-money institutions, and credit unions that issue e-money in the UK. They form the first stage of a wider reform programme, with an eventual CASS-style safeguarding regime expected to replace requirements currently found in the Payment Services Regulations and Electronic Money Regulations.
VinciWorks’ existing Safeguarding: Keeping Our Customers Safe course has been updated to reflect the new regime. It helps employees understand why customer funds must be protected, how safeguarding failures can cause harm and how individual responsibilities support the firm’s wider controls.
Financial promotions remain under close scrutiny
Financial promotions continue to create regulatory risk across websites, social media, customer communications and third-party marketing arrangements. The core requirement remains that promotions must be fair, clear and not misleading. Firms must also consider the Consumer Duty’s consumer understanding outcome and ensure that customers receive the information needed to make effective decisions.
In 2026, the FCA consulted on simplifying parts of CONC 3 and reconsidering how credit costs, including APRs, should be communicated. The proposals would remove some detailed or outdated requirements and place greater reliance on firms delivering good outcomes under the Consumer Duty.
Simplification places greater responsibility on them to decide how information should be communicated to their target audience and to demonstrate that the approach supports customer understanding.
The new Financial Promotions: Meeting the FCA’s Standards course covers the practical application of the rules, including misleading claims, risk information, digital communications, greenwashing and the prevention of financial harm. It is designed for people who create, review, approve or distribute promotional material, rather than treating financial promotions as an issue restricted to the compliance team.
Operational resilience as leadership responsibility
Firms within the FCA’s operational resilience regime were required to be able to remain within their impact tolerances for important business services by 31 March 2025. The focus has since moved towards embedding resilience into normal governance, testing and decision-making.
The FCA’s 2026 observations emphasised the importance of board oversight, clear ownership, effective challenge, scenario testing and meaningful input from the second and third lines of defence. Areas requiring improvement included unclear board engagement, weak review trails and uncertainty over who owned remediation actions.
The new Operational Resilience: FCA Expectations for Leaders course helps senior managers and other leaders understand how to identify important business services, oversee impact tolerances, challenge resilience arrangements and respond when disruption occurs. Its focus is leadership accountability rather than technical business continuity alone.
New FCA courses available from VinciWorks
The newly expanded FCA suite includes:
- Operational Resilience: FCA Expectations for Leaders
- FCA Non-Financial Misconduct: Navigating the COCON Rules
- Financial Promotions: Meeting the FCA’s Standards
- FCA Code of Conduct: Upholding the FCA’s Standards
The existing catalogue has also been reviewed, updated and redesigned. It covers core areas including Introduction to FCA Regulation, Consumer Duty, Treating Customers Fairly, SMCR, vulnerable customers, complaints handling, client money and assets, conflicts of interest, financial sanctions, MiFID, market abuse and safeguarding. Updated knowledge checks support assessment in areas such as MiFID, market abuse and client assets.
Further courses on the horizon
The FCA framework will continue to develop well beyond the September non-financial misconduct deadline. VinciWorks is preparing further courses covering:
- Investment Firms Prudential Regime
- Cryptoassets and Digital Assets: FCA Regulation in Practice
- Consumer Duty for Leaders: Embedding and Evidencing Good Outcomes
- FCA: Talking to Vulnerable Customers: From Warning Signs to Good Outcomes
Crypto regulation is a particularly significant emerging area. The FCA plans to open its gateway for applications for new cryptoasset permissions in September 2026. Final Handbook rules published in June are expected to apply to firms authorised under the new FSMA regime from 25 October 2027. These cover areas including Consumer Duty, conduct standards, SMCR, training and competence, regulatory reporting and cryptoasset safeguarding.
FCA training that changes when the rules change
A regulatory course can become outdated quickly when rules, guidance and supervisory expectations are moving at this pace.
VinciWorks automatically updates its courses whenever relevant legislation, regulation or guidance changes. Firms do not need to wait for the next annual training cycle or commission a complete course rebuild whenever the FCA publishes a new policy statement.
The redesigned FCA suite gives firms a current foundation for general awareness, role-specific training and senior manager accountability. It also allows compliance teams to focus on implementation and evidence, knowing that the underlying training content will continue to reflect the regulatory position.
With the non-financial misconduct deadline approaching and further SMCR, cryptoasset and consumer protection reforms ahead, firms should now review who receives FCA training, whether the content reflects each person’s responsibilities and how completion is recorded. Current training should prepare people to exercise regulatory judgement, rather than simply recognise the terminology.
