Leadership conduct is now the second-largest category for whistleblowing reports received by the Financial Conduct Authority. 

With the FCA’s non-financial misconduct rules set to take effect on 1 September 2026 the data offers an important insight into the evolving landscape of conduct risk and regulatory expectations.

Whistleblowing Reports on the Rise

Between January and March 2026, the FCA received 355 new whistleblowing reports – an increase of approximately 25% compared to the previous quarter (Q4 2025: 281 reports). While this marks a significant quarter-on-quarter rise, it is notable that the volume remains below the peak levels seen in Q3 2025.

Nature of Allegations: Culture and Leadership in Focus

Perhaps the most striking aspect of the data is the nature of the allegations being reported. 

Of the 906 allegations contained within the 355 reports, “Consumer Duty” remains the most frequently cited issue (210 allegations). 

However, “Leadership & senior managers: behaviour, conduct & integrity” now ranks as the second most common category (173 allegations), closely followed by concerns relating to systems and controls, individual conduct, and firm values.

This trend is particularly relevant as the FCA prepares to implement new rules and guidance on non-financial misconduct from 1 September 2026. The prominence of leadership and culture-related allegations suggests that whistleblowers – and, by extension, the regulators – are increasingly focused on behaviours at the most senior levels of firms.

Regulatory Action: A Heightened Response

The FCA closed 265 whistleblowing reports in Q1 2026. In 39% of these cases, the regulator took some form of action, ranging from direct engagement with firms to more formal enforcement steps. Specifically:

• Significant action to manage harm was taken in 9% of cases (e.g. enforcement action, skilled person reviews, or restrictions on permissions).

• Action to reduce harm was taken in 30% of cases (e.g. information requests, firm attestations, or supervisory visits).

• In 51% of cases, the information informed the FCA’s ongoing work, even where no direct action was taken.

This data underscores the FCA’s willingness to act on whistleblowing disclosures and signals that firms should expect greater regulatory engagement where concerns are raised.

Implications for Firms

For boards and senior management, robust conduct and governance frameworks are no longer a matter of best practice – they are a regulatory expectation. 

The increasing focus on leadership behaviour, combined with the FCA’s readiness to intervene, means that firms must ensure their approach to culture and conduct can withstand close scrutiny.

Practical steps include:

• Reviewing and strengthening whistleblowing procedures to encourage early internal reporting.

• Ensuring that conduct risk frameworks are embedded at all levels, with clear accountability for senior management.

• Providing regular training and communication on expected behaviours, particularly in light of the forthcoming non-financial misconduct rules.

• Ensuring managers (SMF holders but also managers at all levels) are trained on the new FCA Rules and Guidance entering into force on 1 September, and particularly on new guidance around “acting with due skill, care and diligence as a manager” (new COCON 4.1.8-A G). 

As the regulatory environment continues to evolve, proactive engagement with these issues will be essential, not only to meet regulatory expectations but to maintain employee trust.