Are Your Hiring Processes Ready for the FCA’s New Expectations?
Effective 1 September 2026, the FCA is introducing updated guidance on the assessment of non-financial misconduct within fit and proper evaluations for certain regulated roles. The changes are important for firms involved in hiring and certification decisions, as they clarify how conduct issues including bullying, harassment, discrimination, threats of violence, and similar behaviours should be considered under the existing SMCR framework.
Importantly, the FCA guidance is clear that firms are not expected to monitor employees’ private lives or social media accounts, or to investigate allegations about private life that are trivial, implausible, or irrelevant. Nor does the guidance suggest that every allegation or instance of poor behaviour should become a regulatory concern. Instead, the focus is on materiality: conduct that could reasonably indicate a wider risk to colleagues, customers, markets, or the integrity of the financial services sector.
For HR, Compliance, and Risk teams, the changes provide an opportunity to review whether current hiring processes are equipped to identify potential risks in a fair, proportionate, and well-documented manner.
Why Social Media Is Suddenly Part of the Conversation
While social media screening is not mandated by the FCA, many regulated firms are reassessing its role within broader hiring and governance frameworks. Traditional screening services such as criminal record checks, employment verifications, and regulatory searches may not always identify behaviours that could be relevant to a fit and proper assessment.
Publicly available online content can, in some circumstances, provide insight into behaviours that align with the types of serious misconduct highlighted in the FCA’s guidance. Examples may include threats of violence, harassment, serious bullying, evidence of criminal activity, or other conduct that could create a genuine regulatory concern.
The key consideration is relevance. The FCA has been clear that lawful personal opinions, political beliefs, lifestyle choices, and protected characteristics should not automatically form part of an assessment. Firms should remain focused on conduct that has a legitimate connection to regulatory expectations and workplace standards.
The Challenges of Doing It Yourself
Many organisations already conduct informal internet searches as part of hiring decisions. However, ad hoc reviews can create governance challenges. Hiring managers may be exposed to protected characteristics, search criteria may vary between candidates, and decision-making can become difficult to evidence during an audit or regulatory review.
As firms prepare for the FCA’s enhanced focus on non-financial misconduct, the question is not whether every organisation should implement social media screening. Rather, it is whether existing processes provide a consistent and defensible approach to identifying potentially relevant conduct concerns.
For organisations that choose to incorporate social media screening into their hiring process, a structured approach can improve consistency, reduce subjectivity, and support stronger governance outcomes.
Preparing for What’s Next
As FCA-regulated firms place greater emphasis on conduct, culture, and fit and proper assessments, many are re-evaluating whether traditional background checks alone provide a sufficiently complete picture of candidate risk. Social Media Screening can help organisations identify publicly available conduct and reputational concerns that may not be captured through traditional screening methods, while providing a more consistent and auditable alternative to informal internet searches.
Want to understand how your organisation can prepare for the FCA’s September changes? Contact Accurate to learn how Social Media Screening can complement your existing screening programme and support a more consistent, defensible approach to regulated hiring.
