Global Trustee and Fiduciary Services Bite Sized Issue 8 2025

15 QUICK LINKS CBDC CRYPTOASSETS CSDR EMIR FINTECH FSB OPEN FINANCE OPERATIONAL RESILIENCE SUSTAINABLE FINANCE/ESG ASIA PACIFIC NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 8 | 2025 The consultations, which have been informed by the regulators’ 2023 Discussion Paper, includes proposals to: • Give firms more time and flexibility to submit applications for approving new senior managers when there has been an unexpected or temporary change. • Strip out duplication where the same individuals are certified for separate functions, which would reduce the number of certification roles by 15%. • Provide guidance on how to streamline the annual checks firms need to undertake to certify individuals are ‘fit and proper’ to do their role. • Allowmore time for firms to report updates to senior manager responsibilities. • Increase how long criminal record checks for senior manager applications are valid for, prior to application submission. • Help firms to better understand the definition of certain SMF roles. • Give firms more time to update the directory, which lists certified staff. The response period for both consultations close on 7 October 2025. Link to FCA’s Consultation Paper here Link to PRA’s Consultation Paper here UK Government Consultation on Reforming the Senior Managers & Certification Regime On 15 July 2025, HM Treasury (HMT) published a consultation paper on reforms to the SM&CR, with the aim of streamlining the regime to support growth and competitiveness. In 2023, the previous government launched a Call for Evidence into the performance, effectiveness and scope of the regime. Responses detailed concerns about the compliance burdens and frictions the SM&CR can cause, especially when appointing new executives. The government is now consulting on legislative changes that aim to reduce regulatory burdens imposed by the SM&CR, without undermining its overall effect to maintain high standards in the financial services sector. The proposed package of measures aims to enable regulators to streamline the SM&CR, while maintaining its role in supporting high standards in financial services firms. It aims to make a significant contribution to reducing the regulatory burdens of the SM&CR by 50%. The proposals and associated questions are set out in the consultation cover: • Chapter 1 provides further background and context to the regime. • Chapter 2 asks for views on proposals to remove the Certification Regime from legislation. • Chapter 3 considers proposals to amend legislation to reform the approach to regulator pre- approval under the Senior Managers Regime. • Chapter 4 asks for views on further measures to ease the regulatory burden of the SM&CR. • The annex provides a full summary of responses to the 2023 Call for Evidence. The response period for the consultation closes on 7 October 2025. Link to Consultation here

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