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1.0 FCA UPDATES & DEVELOPMENTS
On 24 June 2025, the Financial Conduct Authority (FCA) published its Prescribed Persons Annual Report for 2024/25, covering whistleblowing disclosures received between 1 April 2024 and 31 March 2025.
During the reporting period, the FCA received 1,131 whistleblowing reports, resulting in 908 actions, including supervisory engagement and enforcement activity. The most frequently reported issues related to compliance, fitness and propriety, consumer detriment, and organisational culture.
The FCA continues to refine its whistleblowing processes to improve transparency and effectiveness. Key developments include:
- Enhanced feedback mechanisms, allowing whistleblowers to receive more detailed responses where legally permissible.
- Updated online guidance, clarifying the FCA’s remit and improving accessibility for individuals submitting disclosures.
- Ongoing engagement with UK and international stakeholders to explore potential whistleblower incentivisation models, although no formal reward scheme has been introduced.
Whistleblowing reports were most commonly submitted via the FCA’s webform, which remains the preferred channel for disclosures.
Those with a longer memory than the FCA, it seems, will recall the July 2014 Financial Incentives for Whistleblowers note by the FCA and PRA for the Treasury Select Committee where the regulators reported that its research showed that introducing financial incentives for whistleblowers would be unlikely to increase the number or quality of the disclosures they receive.
On 2 July 2025, the Financial Conduct Authority (FCA) published Consultation Paper CP25/18, setting out a new conduct rule and proposed guidance on non-financial misconduct (NFM). The paper includes a Policy Statement confirming changes to the Code of Conduct (COCON) and a consultation on further guidance within both the COCON and Fit and Proper Test (FIT) sourcebooks.
The FCA has confirmed that from 1 September 2026, a new rule COCON 1.1.7FR will apply to non-bank firms, expanding the scope of COCON to cover serious misconduct such as bullying, harassment, and violence that violates dignity or creates an offensive environment. This aligns the treatment of NFM in non-banks more closely with that in banks, where the scope of COCON is broader.
The FCA expects this rule change to result in an increase in conduct rule breach notifications related to NFM, particularly in non-bank firms. However, the application of the rule will be limited where misconduct relates solely to parts of the business not involved in regulated or SMCR financial activities.
The consultation also proposes new guidance to help firms apply the COCON and FIT rules in relation to NFM. Responses to the consultation are due by 10 September 2025.
2.0 REGULATORY REFORM
On 10 July 2025, the Financial Conduct Authority (FCA) announced plans to review its client categorisation rules as part of a broader initiative to unlock investment and support capital markets. The review aims to modernise the classification regime to provide greater clarity on the rules and protections applicable to different customer groups, particularly within wholesale markets.
The FCA intends to rebalance risk and promote a bolder regulatory approach that enables firms to raise capital more easily. The proposed changes are expected to create more opportunities for wealthy and experienced investors, while maintaining appropriate safeguards for retail clients.
This initiative forms part of the FCA’s wider strategy to drive economic growth and competitiveness and builds on other reforms such as the launch of a private stock market (PISCES).
The announcement was accompanied by the FCA’s latest Secondary International Competitiveness and Growth Objective (SICGO) report, which outlines progress made between July 2024 and July 2025. The FCA confirmed that future updates on SICGO will be integrated into its annual reporting cycle.
On 15 July 2025, the Chancellor of the Exchequer delivered her second Mansion House speech, outlining the government’s strategic direction for the UK financial services sector. The speech was accompanied by a series of regulatory announcements aimed at enhancing competitiveness, unlocking investment, and modernising the UK’s financial regulatory framework.
Key developments include:
- The launch of a new Listings Taskforce, in partnership with the Office for Investment, designed to attract more companies to IPO in London and strengthen the UK’s position as a global financial centre.
- A clear signal from the government that it is “rolling back regulation that has gone too far in seeking to eliminate risk”, indicating a shift toward a more proportionate and innovation-friendly regulatory approach.
- Proposed reforms to the Senior Managers and Certification Regime (SMCR), with HM Treasury, the FCA, and the PRA publishing consultation papers to streamline the regime. These changes aim to reduce administrative burden while maintaining accountability standards. For further details, see Waystone UK’s article on the SMCR reform proposals.
- An HM Treasury consultation on the FS Sector Strategy: Regulatory Environment – Cross-Cutting Reforms, which includes a focus on the Consumer Duty. The FCA has been asked to report by the end of September on how the Duty applies to wholesale firms, particularly those involved in distribution chains that impact retail consumers. The consultation also explores professional client categorisation and seeks feedback on how the Duty can be applied proportionately.
These announcements form part of a broader strategy to reshape the UK’s financial regulatory landscape and support long-term growth. For further insights, see Waystone UK’s coverage of the Mansion House speech.