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

9 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 Client journey The suitability test already performed by such firms under existing legislation ensures that clients are recommended investment products suitable to their financial situation, needs and objectives. Under the new simplified framework, however, advisers providing recommendations to consumers related to diversified, non-complex and cost-efficient instruments will no longer have to assess the client’s investment knowledge and experience as part of the suitability assessment. Inducements The package introduces new provisions to spur action in the area of financial literacy, by encouraging member states to help citizens feel more empowered to understand the risks and benefits involved in investing, as well as to critically assess the financial advice they receive. Such actions range from the provision of appropriate financial literacy material for citizens, to ensuring that investment firms’ marketing communication is fair, clear and not misleading. The text also draws particular attention to the activities of financial influencers or ‘finfluencers’ who offer sometimes superficial financial advice, largely through social media. Professional clients The Council says that more experienced investors may not necessarily need the same level of protection as the average retail investor. The updated framework will allowmore retail investors to be treated as professional clients. Such investors will still need to fulfil two out of three criteria to be considered professional: • They carried out 15 significant transactions over the last three years, 30 transactions over the previous year, or 10 transactions over €30,000 in unlisted companies over the last five years (in existing legislation this criterion currently stipulates 10 transactions per quarter over the previous four quarters); • The size of their portfolio has exceeded €250,000 on average over the last three years (currently €500,000 at the moment of their request for exemption); or • They have worked and carried out related activities in the financial sector for at least one year or, in a newly added alternative criterion, can provide proof of education or training in these activities and an ability to evaluate risk. However, the training and education alternative criterion may not be combined with the portfolio criterion to qualify an investor for an exemption. Next steps Technical work will now continue to finalise the legal texts early in 2026. Member states will have to transpose the new rules 24 months following their publication in the EU’s official journal. They will start applying 30 months following their publication, with the exception of the new rules under PRIIPs which would start applying 18 months following their publication. Link to Council Announcement here SAVINGS & INVESTMENTS UNION European Commission Announcement: Market Integration Package On 4 December 2025, the European Commission (Commission) adopted a comprehensive package of measures designed to remove barriers and unlock the full potential of the European Union (EU) single market for financial services. The Commission states that the package is a central component of the savings and investments union (SIU) strategy, aiming to create a more integrated, efficient, and competitive financial system providing EU citizens better options for growing their wealth and supporting businesses in accessing funding.