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

3 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 • Lending and borrowing – Rules to protect both crypto lenders and borrowers; • Decentralised finance (DeFi) – DeFi lets people trade, lend and borrow using crypto without an intermediary. FCA are asking if the same rules that apply in traditional finance should also apply here; and • Prudential requirements – Financial safeguards for firms, so they can better manage risk. The FCA says that these proposals build on feedback from earlier discussions and new research published at the same time as the consultations (see links below). All three consultations are open until 12 February 2026. Link to CP25/40 Webpage here Link to CP25/41 Webpage here Link to CP25/42 Webpage here Link to Research Note: Cryptoassets Consumer Research 2025 here Link to Research Note: Cryptoasset Regulation and Consumer Decision-making: Evidence from an Online Experiment here Link to Draft SI: The Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2025 here Link to SI Explanatory Memorandum here ESMA Issues Statement on MiCA Transitional Measures On 4 December 2025, the European Securities and Markets Authority (ESMA) issued a statement on transitional measures under the Markets in Cryptoassets Regulation (MiCA). ESMA states that MiCA includes a transitional regime for crypto asset service providers (CASPs) that offered their services in accordance with applicable law prior to 30 December 2024. ESMA says that this regime grants them additional time to transition from compliance with the current national regulatory frameworks to compliance with MiCA, while giving individual Member States complete discretion not to apply this transitional regime or to reduce its duration in view of fostering financial stability and investor protection. Considering the fact that (i) some transitional periods have come to an end and that the remaining ones will come to an end shortly and that (ii) market participants have by now had time to benefit from these transitional periods to engage with National Competent Authorities (NCAs) for the purpose of MiCA authorisation, ESMA wishes to set out its expectations for CASPs that are not yet authorised under MiCA. And remind NCAs of what they are expected to do. Link to Statement here EMIR ESMA Statement on Upcoming Reporting Obligations Under EMIR 3 On 11 December 2025, the European Securities and Markets Authority (ESMA) published a Statement, providing clarifications on two key reporting obligations introduced by EMIR 3. Reporting under the Active Account Requirement (AAR) Following the entry into force of EMIR 3 on 24 December 2024, the Active Account Requirement (AAR) became applicable on 25 June 2025 for counterparties meeting the conditions set out under Article 7a(1) of EMIR. To ensure a consistent and effective implementation of the AAR, on 19 June 2025 ESMA submitted to the European Commission draft Regulatory Technical Standards (RTS) specifying the AAR conditions – including reporting obligations for entities subject to the AAR – which were adopted by the European Commission on 29 October 2025 and are currently under scrutiny by the European Parliament and Council. ESMA says that it expects the first reporting submission by entities subject to the AAR to be provided by July 2026. This first submission should include any backlog data demonstrating compliance with the AAR for the period starting 25 June 2025, along with data for 2026.