Global Trustee and Fiduciary Services Bite-Sized Issue 10 2026

5 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 MAS Consults on Legislative Amendments to Implement Stablecoin Regulatory Framework On 1 September 2026, the Monetary Authority of Singapore (MAS) published a consultation paper on proposed amendments to the Payment Services Act 2019 (PS Act) to implement MAS’ regulatory framework for stablecoins in Singapore. The amendments set out how stablecoin issuers may qualify to be MAS-regulated, and the safeguards they must meet to support value stability and user protection. MAS says the MAS Single-Currency Stablecoin (MAS-SCS) framework permits only issuers licensed under the framework to describe themselves as licensed MAS-regulated stablecoin issuers and represent their stablecoins as “MAS-regulated stablecoins”. MAS says that this helps users distinguish well-regulated stablecoins from other cryptocurrencies that purport to be “stablecoins” but are not subject to MAS regulation to keep their value stable. Non-MAS-regulated stablecoins will be treated as Digital Payment Tokens (DPTs) and be subject to the same consumer protection safeguards that apply to DPTs. The consultation paper seeks feedback on the proposed legislative amendments to implement the MAS-SCS framework, including key requirements relating to value stability, capital, redemption at par and disclosure. MAS additionally seeks feedback on policy positions in further areas, taking into account recent developments and best practices in stablecoin regulation internationally. The consultation period closes on 16 October 2026 . Link to MASWebsite here FINTECH ESMA Sets New Supervisory Priority on Digital Innovation From 2027 On 23 September 2026, the European Securities and Markets Authority (ESMA) announced the launch of a new Union Strategic Supervisory Priority (USSP) to help embrace innovation while protecting investors and maintaining strong safeguards. USSPs are ESMA’s convergence tools that address high-risk areas of strategic importance across the EU. They help direct supervisory resources towards the risks that matter most for investor protection, financial stability and the orderly functioning of EU financial markets. ESMA says the digital innovation USSP aims to ensure supervisors have the expertise and capacity to oversee the use of new technologies. In collaboration with National Competent Authorities, ESMA says that its initial focuswill be on howsupervised entities use artificial intelligence (AI) and tokenisation. ESMA says it will remain flexible to address future technological developments as they emerge. The new priority will run alongside the USSP on cyber and operational resilience, which has been in place since 2025. Going forward, ESMA says it will continue its efforts and coordination to address the challenges ahead, including those emerging from advanced models such as frontier AI. Link to Factsheet on USSPs here FUND LIQUIDITY Communication on the Requirement to Notify the “Suspension of Redemption (only)” in the “LMT activation” Module Related to Liquidity Management Requirements On 18 September 2026, the Commission de Surveillance du Secteur Financier (CSSF) issued a communiqué following up on its Communiqué, published on 10 April 2026, detailing the implementation of the “LMT activation” module for notifications of liquidity management tool (LMT) activation and deactivation, as introduced by the liquidity management requirements for funds subject to the Law of 3 March 2026 (the “2026 Law”). The CSSF informs market participants about the extension of the “LMT eDesk procedure” to include, within the “LMT activation” module, the activation and deactivation of suspensions of redemptions (only) under national law provisions applicable to: • Luxembourg-domiciled funds subject to the Law of 17 December 2010 relating to UCIs (the “2010 Law”);