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

21 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 • Making it easier for firms to start up and grow; and • Improving exports and inward investment. Link to FCA Letter to the Prime Minister here Link to PRA Letter to the Prime Minister here FCA Sets Out Landmark Package to Boost UK Investment Culture On 8 December 2025, the FCA has set out a suite of measures to empower retail investment, reinforce wholesale markets and maintain the UK’s position as a world-leading financial centre. With new rules for investment product information, the FCA says that it is playing its part to build a stronger investment culture, supporting firms to innovate and make investing more engaging for consumers. And the FCA is seeking views to make sure regulation supports consumers to invest with confidence. The FCA has announced proposals to enhance how firms classify their clients will give confidence to firms when they deal with professional investors, drawing a line so wholesale markets can remain agile and innovative. The FCA says it has also worked closely with industry and consumer groups to deliver practical policy that moves the dial on risk. Making it easier for consumers to understand investments In retail investment disclosures, the FCA says it will make a decisive shift away from prescriptive and complex templates that consumers don’t find useful. This gives firms more freedom to put the consumer first, innovate, and help their customers understand potential returns as well as costs and risks. The FCA also states that it is seeking views on how longer-term regulation can keep up with the evolving retail investment landscape and help shift the dial on risk appetite, to give consumers confidence to access investments that meet their needs and benefit from the potential returns. Distinguishing between professional and retail The FCA explains that it is setting a clearer boundary between retail and professional investors, allowing firms to deal with professional investors with confidence operating outside retail regulations. This will free up firms to innovate and offer a more diverse range of products to truly experienced clients with the resources to bear more of the risks. The threshold to qualify as a professional investor will remain high, so only those with experience, advice or the ability to bear risk are taken out of retail protections, such as the Consumer Duty, that they don’t need. The FCA says that proposals remove some arbitrary tests and give firms more responsibility to get it right. This includes a new way for wealthy and experienced individuals to opt out of retail protections and streamline how firms assess professional investors. Link to CP25/36: Client Categorisation and Conflicts of Interest here [Closes 2 February 2026] Link to DP25/3: Expanding Consumer Access to Investments here [Closes 6 March 2026] Link to PS25/20: Supporting Informed Decision Making: Final Rules for Consumer Composite Investments here Link to FCA Statement on Firms Working Together to Manufacture Products or Services here HM Treasury Provide Policy Update on Creating a Provisional Licences Authorisation Regime On 4 December 2025, HM Treasury (HMT) published a Policy Update on Creating a Provisional Licences Authorisation Regime. HMT says that as part of the Regulation Action Plan published in March 2025, the UK Government committed to working with the FCA to establish a new authorisation regime which aims to reduce the barriers that financial services firms face when seeking authorisation. HMT states that the proposed ‘provisional licences’ authorisation regime will enable the FCA to grant time-limited permissions so that firms can get ‘up and running’ in a controlled environment with strong regulatory oversight, whilst working towards full authorisation.

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