The FCA’s Consultation Paper CP25/18 marks a pivotal regulatory development for the UK financial services sector. For the first time, serious nonfinancial misconduct — including bullying, harassment, and violence as well as crucially, personal conduct expressed through social media — will be explicitly brought within the scope of the Conduct Rules and the Fit and Proper assessment framework. This move signals a clear shift toward holding individuals accountable for behaviors that undermine trust in the financial sector, regardless of where they occur.
What Does FCA CP25/18 Mean for Graduate Screening?
No longer is misconduct treated purely as an at-work HR matter or addressed only when it reaches the threshold of scandal. Instead, culture, behaviour, and personal integrity are now acknowledged as core components of risk management.
Implications for Recruiting Early-Career Professionals
This FCA’s shift has profound implications for firms recruiting early‑career professionals. Graduates and interns entering the workforce are the first true digital natives in history. They have grown up in a world where their social interactions, opinions, humour, and emotional responses have been expressed and immortalised online, all of which could be taken into considation for hiring decisions where legally permissible.
The Posting Generation and Digital Footprints
Unlike previous generations, younger cohorts have lived their entire personal, social, and educational lives in a posting society. Their friendships play out publicly, their opinions are documented on platforms designed for instant reaction, and their identities are shaped in spaces where the boundaries between private and public conduct may have almost entirely collapsed. In this context, the line between personal expression and professional consequence has become blurred. What a candidate posts at age sixteen may appear again years later when they apply for a role in a highly regulated financial institution. This is not a matter of moral judgement; it is a matter of regulatory relevance. CP25/18 explicitly recognises that behaviour in an individual’s personal life, including on social media, influences their assessments of fitness and propriety.
Challenges in Assessing Early-Career Hires
The challenge for financial services firms may be that early‑career hires may present inherently higher behavioural uncertainty. Experienced professionals arrive with employment histories, references, and patterns of workplace behaviour that can be assessed and verified. Recent graduates and interns rarely have such records. When an individual has not yet been tested within a professional environment, firms must turn to alternative indicators of character, judgement, and risk. Increasingly, these indicators may exist within their publicly observable digital footprint.
Generational Differences in Online Behaviour
Gen Z and Gen Alpha differ from their predecessors not only in their digital fluency but also in the norms surrounding online self‑expression. They have grown up with platforms that reward immediacy, openness, emotional transparency, and experimentation. Social media encourages the performative and the provocative. Posts are often shared impulsively and not deleted because digital presence is often treated as a living diary rather than a curated résumé. As a result, misjudged comments, ill‑considered humour, or problematic affiliations may sit online indefinitely.
Regulatory Recognition of Behavioural Risks
CP25/18 acknowledges the relevance of such online behaviour because non‑financial misconduct can often be a proxy for deeper cultural risk. The FCA’s position is grounded in the understanding that toxic behaviours, whether displayed in person or online, can lead to consumer harm, reputational instability, or broader failings in conduct and market integrity. What happens outside the workplace cannot automatically be dismissed as irrelevant to professional suitability, especially when it speaks directly to issues of respect, integrity, and trustworthiness.
The Importance of Culture in Graduate Hiring
Graduate cohorts represent more than just the next generation of employees; they represent the future culture of the organisation. If behavioural risks are overlooked at the point of entry, they can silently embed themselves into the firm’s culture, maturing into systemic issues that become far harder to correct later. Modern financial services firms are operating under unprecedented scrutiny. With the media spotlight on workplace behaviour and regulators tightening expectations, the reputational cost of hiring individuals whose public behaviour contradicts organisational values should be considered.
The Role of Social Media Screening
Although the FCA does not mandate any specific tools or methods, CP25/18 creates an implicit requirement for firms to have processes capable of detecting behavioural red flags, including those that manifest online. Social media screening should therefore be taken into account and considered as an important component of responsible hiring. When performed ethically and in compliance with privacy and discrimination safeguards, such screening may mitigate risks by identifying publicly visible content that may indicate behavioural risks aligned with the categories defined under CP25/18.
Ethical and Regulatory Considerations in Screening
Screening is not about policing opinions or punishing youthful mistakes; it is about identifying patterns of behaviour that could impact a candidate’s ability to uphold regulatory standards or contribute positively to workplace culture. It provides firms with a structured, evidence‑based approach to assessing whether an individual poses conduct or cultural risk, especially at a stage where other forms of due diligence are naturally limited. It also supports senior managers in meeting their obligations under the Senior Managers & Certification Regime, allowing them to demonstrate proactive cultural oversight and robust documentation of hiring decisions.
Governance and Fairness in Social Media Screening
Modern social media screening solutions incorporate strict governance protocols to help to ensure fairness and regulatory alignment. Only publicly available content is reviewed; protected characteristics are excluded from assessment and human oversight ensures context, nuance, and proportionality. This combination preserves the integrity of the process while enabling firms to meet both regulatory and ethical expectations.
Conclusion: A Cultural Directive for the Industry
CP25/18 represents more than a policy update; it signals a cultural directive for the industry. The boundaries of professional suitability have expanded, and conduct risk now encompasses the totality of a person’s behaviour — not only what occurs within the office walls. Firms that consider screening graduates and interns may not only be better prepared to meet regulatory expectations; they may also assess risks along with the goal to strengthen their culture, protect their reputations, and build a more resilient organisation for the future.
Get in touch with our team to explore how First Advantage can support your organisation navigate the FCA’s influence on graduate and intern screening practices and discover new tools to help assess the posting generation in today’s hiring landscape.
