Global Trustee and Fiduciary Services Bite-Sized Issue 1 | 2026

19 QUICK LINKS AI BENCHMARKS REGULATION (UK) CRYPTOASSETS EMIR FSB FUND LIQUIDITY MIFID/MIFIR IOSCO RETAIL INVESTMENT STRATEGY SAVINGS & INVESTMENTS UNION SUSTAINABLE FINANCE/ESG ASIA PACIFIC EUROPE IRELAND NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 1 | 2026 UNITED KINGDOM FCA Confirms Final Guidance to Tackle Serious Non-financial Misconduct in Financial Services On 12 December 2025, the Financial Conduct Authority (FCA) published Policy Statement PS25/23 ‘Tackling non‑financial misconduct in financial services – Guidance in the Code of Conduct (COCON) and the Fit and Proper test for Employees and Senior Personnel (FIT) sourcebooks’. The FCA says that in July it changed its rules, setting clearer standards for how financial services firms should address non-financial misconduct. The FCA explains that this more closely aligned the rules for banks and non-banks. The FCA are now providing final guidance for this. The FCA says that the guidance covers how firms can apply its rules on minimum standards of behaviour for financial services employees, and the factors they should take into account when assessing whether someone is fit and proper for their role. The FCA have made some small changes to address the main areas of feedback: • New examples and flow charts to support the application of the new rule. • Clearer alignment with employment law. • Clarification that managers’ accountability is relative to their knowledge and authority. • Clarification that firms are not expected to investigate trivial or implausible allegations or breach privacy law. The FCA says its new rules, supported by this guidance, will help drive higher and clearer standards across industry from 1 September 2026. Link to PS25/23 here Regulators Forum Publishes Regulatory Initiatives Grid to Support Innovation and Stability On 11 December 2025, the FCA published the latest edition of the Regulatory Initiatives Grid (Grid), setting out the regulatory pipeline for financial services over the next two years. This edition includes 124 live initiatives, of which 45 are joint initiatives, where there is strong collaboration across regulators and government departments. The Grid also highlights work to support the Government’s Financial Services Growth and Competitiveness Strategy. Key initiatives here include: • Financial stability and regulatory efficiency: Implementation of Basel 3.1 standards, the Strong and Simple framework, Prospectus Regime Reform and Wholesale Markets Review. • Innovation: Supporting the creation of a UK issued stablecoin regime, reforms to the UK captives insurance regime, and the National Payments Vision to deliver world-leading payment solutions. • Consumer confidence and investment: The Advice Guidance Boundary Review and new regulation of Buy Now Pay Later products. Under the Investment Management section of the Grid, there are six live initiatives, two of which are new entries. These are: • Fund tokenisation. • Liquidity risk management in funds. • Improving Money Market Fund resilience as part of UK commitment to Financial Stability Board 2021 review of March 2020 Dash for Cash. • Solo Remuneration Rules Review (NEW) .