Evidencing Culture…
On 1 September 2026, the FCA’s rules and guidance on non-financial misconduct came into force across financial services. For many firms — particularly those beyond the banks now fully in scope — this marks a real shift in what the regulator expects, and in what leaders will personally be held accountable for.
This briefing sets out what changed, why it matters at board level, and what “evidencing culture” now practically requires. It is deliberately short, and free of sales pitch.
What changed on 1 September
- Serious bullying, harassment and violence between colleagues can now fall within the Conduct Rules (COCON), where the seriousness threshold is met.
- Non-financial misconduct is now more clearly relevant when assessing whether an individual is fit and proper, and to the regulatory references firms provide about them.
- These expectations reach all SMCR firms — a far wider population than the banks that have carried them for years.
- Firms are expected to have reviewed their policies, Conduct Rule breach reporting, Fit and Proper processes and references, and to have ensured staff and managers understand the changes.
All of that matters. But it is not the hardest part.
The shift that matters most
The deeper change is one of posture. The FCA has been consistent that it will look beyond written policies to how culture is actually lived — the behaviours people experience day to day, and what happens when someone crosses a line. Stated values and completed training are no longer treated as sufficient evidence in themselves.
That has two consequences for leaders.
First, responsibility for culture now sits unambiguously with senior management, and under SMCR it is personal.
Second — and this is where many firms are quietly exposed — you cannot take responsibility for something you cannot see. Most leadership teams, assessed honestly, are working from anecdote: the loudest voices, corridor conversations, and information that has softened as it travelled up through the organisation. That is not a reliable picture of a culture. It is a picture of what people are willing to say.
From describing culture to evidencing it
Almost every firm can describe its culture. Very few can evidence it — show, with something more solid than assurance, how healthy their culture is, where the risks sit, and how it is changing over time.
Traditional engagement surveys don’t close this gap. They measure how people feel about their jobs, not the behaviours, leadership practices and speak-up conditions the regulator is now focused on.
Evidencing culture, in the sense the new regime implies, means being able to answer questions like these with data rather than opinion:
- If the regulator asked tomorrow, could you demonstrate the health of your culture — beyond policies and good intentions?
- Do your people genuinely feel safe to speak up, and can you show it, not just assert it?
- Where are trust, psychological safety or accountability thinnest — and how do you know?
- How has your culture moved over the past year, by any measure you would stand behind?
- Is that evidence independent enough that a board or a regulator would find it credible?
Firms that can answer these are far better placed — not only for regulatory scrutiny, but for the performance, conduct and retention outcomes that a healthy culture drives.
What “good” looks like
In practice, three things tend to separate the firms that are ready from those that are not:
- Independent measurement, rather than self-assessment a regulator can discount.
- Genuine anonymity, so people answer honestly and you see the real picture rather than the guarded one.
- Trended data, so you can show a direction of travel — an early warning — not just a one-off snapshot.
Together, these turn “we believe our culture is sound” into something a board can stand behind and a regulator will recognise as evidence.
How Cultiv8tiv Financial Services helps
This is the gap Cultiv8tiv Financial Services was built to close.
It is an independent, anonymous culture assessment designed specifically for regulated firms. It measures cultural health across twelve dimensions, aligned to the FCA’s cultural priorities, and produces an overall Culture Pulse Score, detailed results across every dimension, and clear, practical actions. It can serve as an independent external audit — producing findings that stand up as evidence for your board and your regulator.
If it would help to find out more about Cultiv8tiv Financial Services then please click here where you can access a example report OR click here to book a meeting with our CEO, James Leavesley.