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ARTICLE · 29 DECEMBER 2025

UK FCA Issues Final Guidance On Non-financial Misconduct: Judgement Is Essential

Herbert Smith Freehills Kramer LLP
Herbert Smith Freehills Kramer LLP
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Herbert Smith Freehills Kramer LLP

Herbert Smith Freehills Kramer LLP

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On 12 December 2025, the FCA issued its anticipated Policy Statement regarding non-financial misconduct (NFM) in financial services (PS25/23).

United KingdomLitigation, Mediation & Arbitration
Hywel Jenkins
Hywel Jenkins
Jack Moore
Jack Moore
Isobel Salzedo
Isobel Salzedo
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On 12 December 2025, the FCA issued its anticipated Policy Statement regarding non-financial misconduct (NFM) in financial services (PS25/23).

PS25/23 comprises both: the FCA's finalised guidance on NFM; and its response to the feedback it received on its initial proposed guidance in the Consultation Paper 25/18 released in July 2025 (CP25/18).

We published our analysis of CP25/18 and draft guidance in July.

Calls for guidance

The FCA had said that it would only publish the guidance if it was wanted. As predicted, the desire for guidance on the changes to NFM rules was almost unanimous, with 95% of respondents agreeing that guidance was needed to help firms apply the NFM rules. We agree that this guidance is useful to have, even if not dealing with all scenarios.

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