
Contents
- 1What is FCA compliance training?
- 2Which firms need FCA compliance training?
- 3SM&CR training requirements in 2026
- 4Consumer Duty training obligations
- 5Conduct Rules training: scope, evidence and reporting
- 6Non-financial misconduct: the September 2026 change
- 7Common FCA training failures and what they cost
- 8How to build an FCA-compliant training program in 2026
- 9Why microlearning beats annual e-learning for FCA compliance
- 10Conclusion
- 11FCA compliance training FAQs
- 12Sources
FCA compliance training is a legal duty, and the regulator judges it on evidence, not attendance. Section 64B of the Financial Services and Markets Act 2000 requires firms to tell staff which conduct rules apply to them and take all reasonable steps to make sure they understand them, with suitable training named as one of those steps. In 2026 that covers the SM&CR, the Consumer Duty, the Conduct Rules, financial crime, and, since 1 September 2026, serious non-financial misconduct at non-bank firms.
- Training is built into the law. Section 64B FSMA makes "suitable training" part of the duty to help Conduct Rules staff understand how the rules apply to them.
- The SM&CR reforms didn't relax accountability. PS26/6 changed processes and thresholds from April 2026. It didn't remove the duty to make sure people understand the rules.
- Non-financial misconduct is now in scope. From 1 September 2026, serious bullying and harassment can breach the Conduct Rules at non-bank firms too.
- Completion isn't competence. Records should show the training was role-specific, current and understood.
- Short, frequent training fits the way rules change. A year-long gap between refreshers doesn't.
The FCA's published list of 2024 fines totals £176 million, more than three times the 2023 figure. The big cases keep coming back to the same themes: controls that didn't keep pace with the business, and people who didn't know what the rules meant for their own job.
That's the gap this guide is about. The expectations are spread across several frameworks, and the dates keep moving. Below you'll find what each one requires, where firms trip up, and how to build training that stands up when a supervisor asks for proof.
What is FCA compliance training?
FCA compliance training is everything a regulated firm does to make sure its people can do their jobs within the rules. That means conduct standards, individual accountability, customer outcomes and financial crime prevention. It spans several frameworks at once and runs all year, not as a single course or annual exercise.
The FCA doesn't prescribe a format. It does expect firms to employ people with the skills, knowledge and expertise their roles demand (SYSC 5.1 in the FCA Handbook). Where a firm advises or deals with retail clients, the Training and Competence sourcebook (TC) adds more detail.
In practice, a 2026 program has four pillars:
- SM&CR obligations for Senior Managers, Certified Persons and Conduct Rules staff.
- Consumer Duty understanding for anyone who shapes or delivers customer outcomes.
- Conduct Rules, including the extension to non-financial misconduct.
- Financial crime, covering anti-money laundering, sanctions, fraud and market abuse, which sits alongside the other three with equal weight.
Authorised persons must notify relevant persons of the conduct rules that apply to them and take all reasonable steps to make sure they understand how those rules apply. The steps needed include, in particular, the provision of suitable training.
Source: legislation.gov.ukWhich firms need FCA compliance training?
Every FCA-authorised firm has training obligations. The depth varies with the firm's type, size and activities, but no regulated firm is exempt.
Under the SM&CR, firms fall into three categories: Limited Scope, Core or Enhanced. Enhanced firms are the largest and most complex, and PS26/6 raised the thresholds for that category from 10 July 2026. Most FCA-regulated businesses sit in Core. Limited Scope firms have lighter requirements, but Conduct Rules training still applies to them.
| Category | Who falls in | Training focus |
|---|---|---|
| Enhanced | The largest, most complex firms | Senior Manager, Certified Person and Conduct Rules training, plus the extra accountability requirements for the category |
| Core | Most FCA-authorised firms | Senior Manager and Certified Person training, and Conduct Rules training for all relevant staff |
| Limited Scope | Smaller, simpler firms | Conduct Rules training, with lighter Senior Manager and certification requirements |
Consumer Duty obligations apply to firms that deliver products or services to retail customers. Financial crime training applies to anyone inside the regulated sector under the Money Laundering Regulations 2017.
SM&CR training requirements in 2026
The Senior Managers and Certification Regime is the FCA's framework for individual accountability. Everyone in a regulated role sits somewhere in it, and each group needs different training.
Senior Managers
Senior Managers hold FCA-approved functions. Their training should cover their Statements of Responsibilities, the four Senior Manager Conduct Rules and what "reasonable steps" looks like when something goes wrong. Personal liability follows the individual, so abstract awareness isn't enough. They need to understand it in terms of their own business area.
Certified Persons
Certified staff perform functions listed under SYSC 27. The firm has to assess their fitness and propriety and issue a certificate every year. Training should support that assessment through the year, not just at onboarding. A module ticked off twelve months ago doesn't show anyone is still competent today.
Conduct Rules staff
Most of your workforce falls here. They need to understand how the Conduct Rules apply to their role specifically. A generic slide deck about integrity won't do. A mortgage adviser and a payments operations analyst face different risks, and the training should show it.
PS26/6, the first phase of the SM&CR review, took effect on 24 April 2026, with some changes following on 10 July 2026. It streamlines processes such as notifications and certification overlaps. Section 64B sits in primary legislation, so a change to FCA rules doesn't remove it. Treating the reforms as permission to cut training is a mistake.
Consumer Duty training obligations
The Consumer Duty has applied since July 2023. It's built around four outcomes: products and services, price and value, consumer understanding, and consumer support. Staff in customer-facing, advisory and product roles need to know what a good outcome looks like in their own job, not in the abstract.
The FCA hasn't gone quiet on the Duty. Its Consumer Duty hub keeps adding good and poor practice reviews, including ones published in September and October 2026 on payments firms, contracts for difference and fair value in consumer finance. If you train once and file it, you're relying on a snapshot while the supervisory picture keeps moving.
Two habits make Consumer Duty training stick:
- Feed outcomes data back into content. Complaints, call reviews and chat transcripts show where customers get confused. Turn those patterns into short lessons.
- Brief the board on what people learned, as well as who finished. It's easier to show a supervisor that you're acting on evidence if the evidence already exists.
The Duty also has a conduct-rule edge. Individual Conduct Rule 6, "You must act to deliver good outcomes for retail customers," applies where the firm's activities are covered by the Duty.
Conduct Rules training: scope, evidence and reporting
The Individual Conduct Rules apply to most people working in an authorised firm. Four further rules apply to Senior Managers only. Section 64B names suitable training as a step firms must consider, so it is the usual way to meet the duty.
| Rule | Wording | Applies to |
|---|---|---|
| Rule 1 | You must act with integrity. | All Conduct Rules staff |
| Rule 2 | You must act with due skill, care and diligence. | All Conduct Rules staff |
| Rule 3 | You must be open and cooperative with the FCA, the PRA and other regulators. | All Conduct Rules staff |
| Rule 4 | You must pay due regard to the interests of customers and treat them fairly. | All Conduct Rules staff |
| Rule 5 | You must observe proper standards of market conduct. | All Conduct Rules staff |
| Rule 6 | You must act to deliver good outcomes for retail customers. | Where the Consumer Duty covers the firm's activities |
Good training helps people recognize when a rule applies to their role, what a breach looks like in practice, and what to do when they see one.
Reporting is narrower than most people assume. Senior Managers' firms must notify the FCA within seven business days of concluding disciplinary action for a Conduct Rule breach. For other Conduct Rules staff, firms report breaches that resulted in disciplinary action once a year. Disciplinary action means a formal written warning, suspension, dismissal, or a reduction or recovery of pay.
On evidence, a screenshot of 100% completion isn't a strong answer to "how do you know they understood?" Firms should be able to show that training was role-specific, tested for understanding and refreshed when the rules changed.
Non-financial misconduct: the September 2026 change
On 1 September 2026, the FCA's amendments to the Code of Conduct (COCON) took effect, extending the Conduct Rules to serious work-related non-financial misconduct at non-bank firms, with guidance published in PS25/23. Banks were already covered. The conduct caught includes bullying and harassment that violates a colleague's dignity or creates an intimidating, hostile, degrading, humiliating or offensive environment.
The bar is high. Minor incidents that don't have that purpose or effect aren't breaches, and the FCA aligned the seriousness threshold with the Equality Act's definition of harassment. That doesn't make it a policy-only issue, though. Managers carry real exposure.
Under the guidance, managers aren't held responsible for failing to prevent misconduct they couldn't reasonably have known about, or couldn't act on. The examples of reasonable steps are practical: intervene to stop inappropriate behavior, take complaints seriously, and make it safe to speak up. That's a training brief in itself.
The rules are already live. Check that your bullying and harassment policy matches the new scope, that Conduct Rules staff have been told about the change, and that managers have had their own scenario-based module on what reasonable steps look like.
Separately, the "all reasonable steps" duty to prevent sexual harassment under the Employment Rights Act 2025 started on 30 October 2026. It applies in Great Britain and amends the Equality Act 2010, so it overlaps with the FCA's expectations in the same places.
Common FCA training failures and what they cost
Enforcement shows where programs break down. The pattern is usually growth outrunning controls.
Starling Bank was fined about £29 million in 2024 for failings in its financial crime systems and controls and for breaching a voluntary requirement. Monzo was fined £21.1 million in July 2025. The FCA found weak customer due diligence and transaction monitoring, and Monzo opened more than 26,000 high-risk accounts in breach of a restriction. Mishcon de Reya's summary of the Final Notice notes that staff were poorly trained and under-resourced.
It's tempting to read those cases as stories about big banks. Smaller firms face the same test, scaled down: do the people doing the work understand the rules well enough to spot a problem, and would your records show it if the FCA asked?
The lesson is that financial crime knowledge has to scale with the business. Products change, customer volumes grow and typologies shift. Onboarding-only training can't keep up.
Under the Money Laundering Regulations 2017, relevant employees must be regularly trained to recognize and deal with money laundering risks, and the firm must keep a written record of that training. Check that your record shows who was trained, on what, and when.
How to build an FCA-compliant training program in 2026
An FCA-compliant program is a structured, role-mapped system that produces evidence as it runs. Here's the order that works.
Map your population
Identify who's a Senior Manager, a Certified Person or Conduct Rules staff, and who's covered by the Consumer Duty and the Money Laundering Regulations. Keep the mapping on file. A supervisor may ask for it.
Assess needs by role
Each job needs its own view of which rules apply, what they mean day to day and what a breach would look like.
Cover all four pillars
SM&CR, Consumer Duty, Conduct Rules including non-financial misconduct, and financial crime. A gap in one pillar is a gap in your defense.
Deliver little and often
Short sessions let you roll out new guidance quickly and keep knowledge fresh between formal refreshers.
Build the evidence trail
Keep records that are role-specific and timestamped. Add assessment results and a log of how content changed after new FCA guidance. If you need to prove it, you'll be glad it's there.
Plan for regulatory change
2026 alone brought PS26/6 in April and July, the non-financial misconduct rules in September and the harassment duty in October. Decide who owns each update and how fast it reaches learners.
| Group | Training focus | Evidence worth keeping |
|---|---|---|
| Senior Managers | Statement of Responsibilities, Senior Manager Conduct Rules, reasonable steps | Scenario results and board or committee records |
| Certified Persons | Role competence, fitness and propriety, Conduct Rules in practice | Training linked to the annual certification review |
| Customer-facing staff | Consumer Duty outcomes, vulnerable customers, Conduct Rule 6 | Assessment results and refresher dates |
| Managers | Non-financial misconduct, speaking up, reasonable steps | Completion of the manager-specific module |
| Financial crime roles | AML, sanctions, fraud, market abuse | Written record of who was trained, on what, and when |
Three mistakes show up again and again. Firms train everyone on the same generic content, so nobody sees their own job in it. They treat the annual module as the program, so updates wait months. And they keep completion data in one system and policy changes in another, so nobody can show how the two connect. Fixing those three gets you most of the way.
Role-specific courses help here. 5Mins has FCA-focused courses on the Senior Managers and Certification Regime, the FCA Code of Conduct, the Consumer Duty and anti-money laundering.
Why microlearning beats annual e-learning for FCA compliance
A standard annual module asks people to absorb a year of regulation in one sitting, then leaves them alone for the next eleven months. The FCA doesn't ask whether you ran a course. It asks whether people are competent and whether your controls work.
5Mins delivers 95%+ completion, against completion under 5% on a legacy LMS. For a financial services example, AZA Finance lifted training participation from 30-40% to 80% (see the AZA Finance customer story). The platform offers 500+ accredited compliance courses within a library of 20,000+ microlessons, and compliance content is kept up to date as regulations change. Managers get a Team Progress Email showing their team's overdue courses and those due in the next 30 days, and learners get reminders in Slack, Microsoft Teams, email and push.
| Factor | Annual legacy LMS module | |
|---|---|---|
| Completion | 95%+ | Under 5% |
| Typical lesson | Microlessons of about 5 minutes | One long module a year |
| Content updates | Kept up to date as regulations change | Often waits for the next annual cycle |
If you'd rather turn your own policies into training, AI Studio includes an AI Course Creator and a Video Creator, and most documents become a video in about 10 minutes. You can also build practice scenarios with AI Roleplays, with each attempt scored out of 100 against a rubric you can edit.
Conclusion
FCA compliance training in 2026 comes down to one question: can you show your people understand the rules that apply to them? Section 64B sets the duty, PS26/6 hasn't changed it, and the non-financial misconduct rules have widened what it covers.
Map the roles, train in short regular bursts, keep records that show understanding rather than attendance, and have a named owner for each regulatory change. Do that and your next supervisory conversation gets much easier.
FCA compliance training FAQs
Is FCA compliance training mandatory?
Yes. Section 64B FSMA 2000 requires authorised firms to notify relevant persons of the conduct rules that apply to them and take all reasonable steps to make sure they understand how the rules apply, naming suitable training as one of those steps. The Money Laundering Regulations 2017 separately require regular training for relevant employees, with a written record.
What training does the SM&CR require in 2026?
Senior Managers need training on their Statements of Responsibilities and the Senior Manager Conduct Rules. Certified Persons need training that supports their annual fitness and propriety assessment. Other Conduct Rules staff need role-specific training on how the Individual Conduct Rules apply to them.
How often should FCA compliance training be refreshed?
The FCA doesn't set a fixed frequency. Refresh whenever the rules or your risks change, and keep short refreshers running between formal updates. In 2026 that has meant at least the PS26/6 changes, the non-financial misconduct rules and any guidance specific to your business.
What evidence should we hold on training?
Keep timestamped records showing who was trained, on what and when. Add assessment results, the role the training was designed for, and a log of how content changed after new FCA guidance. Under the Money Laundering Regulations 2017 you must keep a written record of AML training.
Do the PS26/6 reforms reduce training obligations?
No. PS26/6 changed processes and thresholds, effective from 24 April 2026 with some changes from 10 July 2026. The section 64B duty is in the Act, and the accountability regime remains in place.
What does the non-financial misconduct change mean for training?
Since 1 September 2026, serious work-related bullying and harassment can breach the Conduct Rules at non-bank firms. Update your policy, tell Conduct Rules staff, and give managers their own training on reasonable steps to prevent and address misconduct in their teams.
Sources
- Financial Services and Markets Act 2000, section 64B, legislation.gov.uk
- 2024 fines, FCA
- FCA fines Starling Bank £29m for failings in their financial crime systems and controls, October 2024, FCA
- PS26/6: Senior Managers and Certification Regime review, FCA
- FCA finalises non-financial misconduct guidance and confirms September 2026 implementation, Linklaters
- Conduct Rules, FCA
- Money Laundering Regulations 2017, regulation 24, legislation.gov.uk
- Consumer Duty, FCA
- FCA fines Monzo £21 million for failings in anti-money laundering systems and controls, Mishcon de Reya
- 2023 fines, FCA
- Workplace sexual harassment and third-party harassment, business.gov.uk
- Senior Managers and Certification Regime, FCA
This article gives general information on FCA compliance training requirements as of November 2026. It isn't legal advice.
Madlena (Maddie) Pozlevic
Customer Success Lead, 5Mins
Maddie leads customer success at 5Mins.ai, helping teams move from box-ticking training to learning cultures that actually stick. She has worked hands-on with companies across industries to drive adoption, cut time-to-value, and make sure learners, and the managers tracking them, never have to wonder if training is working.
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