As the UK insurance sector braces for landmark reforms around non-financial misconduct, Jacqueline Girow (pictured), executive director of LIIBA, says the industry is approaching a pivotal moment in redefining how it governs behaviour, culture and accountability. "Whatever the outcome" of current high-profile cases, she said, "this sends a very strong message that board decisions must stand up to scrutiny."
While many firms are aware of the Financial Conduct Authority's incoming rules, Girow warns that few fully grasp the operational impact. "This goes from an individual's own behaviours to the actions now expected of a board," she said, pointing to changes beyond FCA regulation. New legislation tied to amendments to the Employment Rights Act 1996 will impose tougher responsibilities: from June 2026, protections will extend to whistleblowers reporting sexual misconduct; and by September, firms must take "all reasonable steps" to prevent harassment, including from third parties.
"That means being far more proactive," she said. "Firms will need to assess where employees may be at risk and demonstrate prevention."
These moves reflect a broader cultural shift across UK industries, Girow noted, with expectations rising around corporate ethics and governance. For insurance firms, the spotlight is particularly intense due to the historic power dynamics and hierarchies embedded in the London market.
Cross-market collaboration has become a cornerstone of LIIBA’s response. Alongside the IUA and LMA, LIIBA launched non-financial misconduct (NFM) workshops following the FCA's Section 165 review. "The challenges are the same across broking and underwriting," Girow said. She reiterated what Padda Consulting, who delivered the workshop series, had confirmed, "Most firms don’t lack policies; they lack trust that those systems will protect people."
The workshops revealed a consistent concern: cultures tend to erode not from dramatic scandals, but from "small challenges that go unchecked." This insight has spurred LIIBA to tailor support for SME broker firms, which face unique resource and governance hurdles.
Girow emphasised that the new requirements cannot be met through compliance exercises alone. "The role of compliance and HR is to inform the board, but the board has to own how culture permeates," she said. "They need to be ready to enact change, even when that means difficult choices."
In 2026 and beyond, Girow believes trust will become the defining measure of cultural health. "If people can’t raise concerns about those with the most influence, the firm doesn't have a functioning speak-up culture."
To that end, LIIBA is partnering with Inclusio, a culture data specialist, to pilot a proof-of-concept initiative with select SME firms starting in January. "We want to go beyond saying what’s coming down the line," she said. "We want to offer practical help."
The road to 2026 will test how seriously firms take cultural accountability. While some pushback remains around the FCA’s role in regulating non-financial behaviour, Girow is unequivocal: "Conduct is everyone’s responsibility - government, regulator, firm, and individual."
The path forward will demand uncomfortable conversations, better data, and a willingness to act when the easier option is to stay silent.
