Global Trustee and Fiduciary Services Bite-Sized Issue 11 2025

20 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 The BoE also says that following industry feedback, these changes go further than original proposals announced last year and that the PRA/FCA will also allow part-payment of bonuses for the most senior bankers from year one, rather than year three as it was previously. The new rules came into force on 16 October 2025, in time for 2025 pay awards and any other awards made but not yet fully paid. Additional changes from the regulators include: • Lifting restrictions on the proportion of bonuses that need to be deferred, going further than at consultation. Previously, 60% of the full amount of any bonuses above the £660,000 threshold needed to be deferred. Now only 60% of amounts above that threshold will need to be deferred. • New rules to give firms more flexibility to allow a greater share of the cash element of bonuses to be received up front. More of the component comprised of shares and other instruments can now be deferred, which helps promote responsible risk-taking. Previously, both the upfront and deferred components of bonuses had to be 50% cash and 50% instruments. Finally, the BoE says that the rules also introduce greater alignment with the Senior Managers Regime, so that firms consider performance against PRA supervisory priorities in the bonus payouts of the responsible Senior Managers. Link to Policy Statement here Red Tape Slashed by 70%Under FCA’s NewCapital Rules On 15 October 2025, the Financial Conduct Authority (FCA) published its Policy Statement on ‘Definition of Capital for FCA Investment Firms’ (PS25/14). The reforms align with the government’s regulatory reform agenda, including the Edinburgh and Leeds Reforms and deliver on commitments made when the Investment Firms Prudential Regime was introduced in 2022. The FCA says that the new rules do not change the overall levels of regulatory capital firms must hold or require firms to alter their capital structures. Instead, they: • Clarify what qualifies as own funds; • Reduce unnecessary complexity; and • Remove provisions designed for banks that are not relevant to investment firms. The FCA says that it does not expect firms to change their capital arrangements because these reforms maintain existing capital standards and eligibility criteria. However, firms may need to consider the clarifications provided and update internal documents with new rule references. The new rules will come into effect on 1 April 2026. Link to PS25/14 here