Global Trustee and Fiduciary Services Bite-Sized Issue 10 2026

9 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 • The value of frontier AI depends on the firm’s operating environment: Firms testing frontier AI models for cyber resilience report that the value they get from them is determined less by what models are being used and more by the governance, tooling, controls, human oversight and operational environment they’re in (the harness). • Frontier AI is making foundational cyber and operational resilience more important: Frontier AI is exposing firms’ weaknesses in their vulnerability management practices, access management controls, dependency mapping and remediation processes. Firms that do basic cyber-resilience practices well, and have clear accountability and effective oversight, are likely to be better positioned to tackle the challenges frontier AI brings. • Effective governance and human judgement remain critical: While frontier AI can significantly speed up many processes, firms continue to rely on human oversight to prioritise action and manage risk. The FCA says senior leaders may need greater visibility of how AI affects remediation capacity, operational resilience and risk, and their firm’s ability to continue delivering important business services. Link to the Review here SUSTAINABLE FINANCE/ESG HKMA Publishes New Supervisory Policy Manual (SPM) Module GS-2 on “Transition Planning” On 22 September 2026, the Hong Kong Monetary Authority (HKMA) issued a circular notifying Authorised Institutions (AIs) that, following two rounds of industry consultation, it had issued a new SPMmodule GS-2 on “Transition Planning” as a guidance note. The HKMA says that, following the issuance of SPMmodule GS-1 on “Climate Risk Management” in 2021, there have been regulatory developments in climate risk management, particularly in transition planning. As such, the HKMA says it considers it timely to set out relevant considerations and provide guidance to AIs on enhancing their resilience and managing the risks and opportunities associated with the net-zero transition in a new SPMmodule. The new SPM module, GS-2, also supports the vision of “Banking for net zero” set out in the Sustainable Finance Action Agenda launched by the HKMA in 2024. The HKMA says that, consistent with GS-1, GS-2 applies to all AIs and is risk-focused. While certain concepts and elements in GS-2 have already been included in GS-1, GS-2 elaborates on and supplements GS-1. AIs should therefore read this module in conjunction with GS-1 and any applicable modules when implementing GS-2. The HKMA says that the primary objective of GS-2 is for AIs to establish a robust and proportionate transition planning process. The HKMA says it will adopt a proportionate and pragmatic approach when assessing AIs’ implementation, considering the size, nature and complexity of each AI’s operations, the materiality of climate-related risks the AI is exposed to, and the practical challenges that AIs face in transition planning. The HKMA says that AIs should take an iterative approach to implementing the requirements set out in GS-2. To facilitate and guide their transition planning, AIs should have transition planning documentation in place by 1 July 2030. After 24 months of the issuance of GS-2, AIs should be prepared to demonstrate their progress in implementing GS-2 and demonstrate their readiness to have their transition planning documentation in place by 1 July 2030. To assist AIs’ preparation of transition planning documentation, the HKMA says it will provide, for informational and reference purposes only, examples of information at a future date that AIs may consider including in their transition planning documentation. AIs shouldbe prepared todemonstrate their progress in implementingGS-2 from 22September 2028 . AIs should have transition planning documentation in place by 1 July 2030 . Link to GS-2 Transition Planning here Link to the Sustainable Finance Action Agenda here