Research & Insights
Beyond compliance: what the FCA’s misconduct rules mean for your next leadership hire.
Approvable or Fluent?
Succession Starts Before the Resignation
The FCA’s non-financial misconduct rules took effect on 1 September 2026, extending coverage of serious workplace misconduct to around 37,000 non-bank firms. Serious, substantiated cases must also be disclosed through regulatory references, making it harder to leave a conduct record behind by changing employers. For boards and hiring teams, this raises questions beyond compliance: how should an adverse reference be interpreted, what evidence demonstrates rehabilitation, and when should a concern rule out an appointment? The challenge is not simply obtaining the reference, but exercising sound judgement about what it means for the next hire.
Boards need non-executives who can challenge AI and cyber risk, not simply satisfy governance criteria. An approvable director is not necessarily a technically fluent one.
Look beyond titles to CIOs and CTOs with regulated-sector experience, or former regulators with genuine technical depth. Test independence, judgement and technical fluency together.
Before building the longlist, define what the role must deliver. The question is not simply who is available, but what they must challenge and who will be accountable.
The boards I advise rarely have a candidate problem. They have a preparation problem.
Prepare potential successors through broader responsibility, review readiness quarterly, and identify interim cover before a vacancy appears.
If your CEO resigned today, who takes over tomorrow, and who is ready permanently? If the only answer is a search firm’s number, you have a recruitment response, not a succession plan
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