Global Trustee and Fiduciary Services Bite-Sized Issue 10 2026

4 AIFMD CRYPTOASSETS FINTECH FUND LIQUIDITY OPERATIONAL RESILIENCE SUSTAINABLE FINANCE/ ESG T+1 ASIA PACIFIC EUROPE NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 10 | 2026 Quick Links • Firms already authorised that may need extra permissions; • Firms registered under the Money Laundering Regulations (MLRs); • Issuers of electronic money and payment service providers; • Traditional finance firms exploring cryptoasset markets; and • Overseas firms providing cryptoasset services to UK consumers. The FCA says it plans to consult on further changes to its perimeter guidance in late 2026, following a government statutory instrument amending the underlying regulations. It aims to publish that guidance in early 2027. Link to PS 26/18 here Tokenisation inWholesale Markets On 14 September 2026, the FCA published Feedback Statement FS26/1: Tokenisation in Wholesale Financial Markets, following the joint FCA and Bank of England (BoE) Call for Input on the future of tokenisation, published on 18 May 2026, asking for industry views on the benefits, priorities and barriers for tokenised securities in UK wholesale markets, with the aim of giving firms the regulatory clarity the industry needs to invest and scale up. The FCA says respondents supported its proposed approach, and most agreed that post-trade is the main opportunity, particularly improving how collateral moves between parties. The FCA says it will use this feedback to develop a joint tokenisation roadmap with the BoE, later in 2026. The roadmap will set out target dates for their work on wholesale tokenisation. The FCA says it plans to consult on rules for safeguarding relevant specified investment cryptoassets (RSICs) in the first half of 2027. Link to FS26/1 here Call for Input: Tokenised Gold – Opportunities and Risk for UKWholesale Markets On 14 September 2026, the FCA published a call for input seeking views on whether tokenising gold could improve how it is traded, transferred, pledged and held in UK markets. The FCA says it wants to understand whether tokenising gold could boost efficiency and competitiveness, while maintaining market integrity and protecting consumers. The FCA says it is particularly interested in understanding: • Use cases in wholesale markets; • Specific areas which may prove challenging; and • The impact of perceived uncertainty around the collective investment scheme (CIS) and alternative investment fund (AIF) regulatory perimeter. The FCA says that the call for input is aimed at: • Asset managers and firms operating gold CISs or AIFs; • Gold market participants, including clearing members; • Firms developing or considering tokenised gold products; • Technology and infrastructure providers working on digital asset platforms; • Consumer groups and investors interested in gold-backed products; and • Stakeholders interested in tokenisation of other commodities. The call for input closes on 23 October 2026 . Link to the Call for Input here