Global Trustee and Fiduciary Services Bite-Sized Issue 11 2025

12 QUICK LINKS AIFMD CBDC CRYPTOASSETS DIGITAL ASSETS FINTECH FSB MIFID/MIFIR (UK) IFR/IFD OPERATIONAL RESILIENCE OUTSOURCING SUSTAINABLE FINANCE/ESG T+1 TOKENISATION ASIA PACIFIC EUROPE NETHERLANDS NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 11 | 2025 • In 2027, the FCA expect all firms to be testing (both internally and with any external parties) their amended settlement processes to ensure they are ready to settle on a T+1 basis from 11 October 2027. Link to FCA Letter here ESMA Proposes Key Reforms to Settlement Discipline, Supporting the Transition to T+1 On 13 October 2025, the European Securities and Markets Authority (ESMA) published its final report recommending significant amendments to the Regulatory Technical Standards (RTS) on Settlement Discipline. ESMA says that these changes aim to enhance settlement efficiency across the EU, facilitate the transition to a shorter settlement cycle (T+1) by 11 October 2027 and reduce the administrative burden on central securities depositories (CSDs) and market participants. The proposed changes are designed to improve operational readiness of the EU financial industry and include: • Same-day (trade date) timing for trade allocations and settlement instructions; • Machine-readable formats for allocations and confirmations; • Mandatory implementation of key functionalities such as hold and release, auto-partial settlement, and auto-collateralisation; • Updated provisions for the monitoring and reporting of settlement fails; and • A phased-in implementation schedule, beginning in December 2026 and concluding by 11 October 2027, intended to ensure a smooth transition to the new regime. ESMA strongly encourages market infrastructures, financial intermediaries and their clients to treat these regulatory changes as a central element of their T+1 transition strategy. The draft amendments have been submitted to the European Commission, which has three months to decide on their adoption. Link to Final Report here TOKENISATION FCA Supports Tokenisation to Boost Efficiency and Innovation in Asset Management On 14 October 2025, the Financial Conduct Authority (FCA) published a Consultation Paper on ‘Progressing Fund Tokenisation’ (CP25/28), which the FCA says contains its proposed new rules for fund tokenisation and direct-to-fund dealing. CP25/28 also sets out how the FCA aim to support innovation in UK asset management, while protecting consumers. The FCA’s key proposals include: • Guidance for operating a tokenised fund under the Blueprint model; • Introducing an optional newmodel for direct dealing in conventional and tokenised authorised funds; • A roadmap to advance fund tokenisation and address key barriers; and • A discussion on future tokenisation models that use DLT to provide tokenised portfolio management at retail scale and how regulation may need to change to be fit for the future. The FCA says that its proposals aim to give firms greater clarity and thus the confidence to adopt tokenisation in fund management to improve operational efficiency and to gather insight and provide a roadmap on how its rules may need to evolve in future. The FCA adds that its objective is to allow fund managers flexibility to operate funds in the most efficient way and enhance the competitiveness of the UK as a global hub for asset management.