HM Insights

Financial Conduct Authority publish expectations around remote and hybrid working

This week, the Financial Conduct Authority (“FCA”) published a list of expectations for regulated firms in relation to remote and/or hybrid working. Although the specific expectations outlined are relevant only to FCA regulated firms, the general issues covered by this new guidance are likely to be important for all businesses seeking to integrate hybrid and remote working as a more permanent aspect of their practice.


We’ve reviewed the FCA expectations, and have picked out three main points in this guidance that all businesses should consider as they review remote and hybrid working practices with the view to retaining them long-term.

Firm Operations

It is important businesses assess the impact of hybrid and remote working on the operations of the firm. Businesses should seek to evaluate the differences in managing operations from a centralised location compared with remote working. Thought should be given to matters such as the impact a lack of centralised location may have on ability of the firm to oversee its functions and any detriment to consumers or clients of the business.


If a firm has concluded that they wish to make the temporary practice of hybrid/remote working a fixed aspect of the business, there should be appropriate planning for this. Such planning should include in relation to the appropriate record keeping, culture, and the effect on staff, including wellbeing, training and diversity and inclusion matters. Any temporary arrangements should be reviewed and assessed before they are made permanent.

Continued compliance with standards and protection of information

Hybrid and remote working does create additional security and protection of confidential information risks. Whilst many of the requirements in the FCA guidance are relevant only to regulated companies, all businesses must consider data, cyber and security risks, particularly as staff may transport confidential material and laptops more frequently in a hybrid arrangement.

We’ve been advising a significant number of clients in all sectors regarding the approach to hybrid working including in relation to policies, contractual changes and matters such as the above. Please get in touch with one of the employment team if you’d like to discuss how we can assist your business with this process.