Global Trustee and Fiduciary Services Bite-Sized Issue 4 2026

11 QUICK LINKS CMU CONDUCT CRYPTO ASSETS EMIR FINTECH FUND LIQUIDITY IOSCO OPERATIONAL RESILIENCE SUSTAINABLE FINANCE/ESG T+1 ASIA EUROPE LUXEMBOURG NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 4 | 2026 Alongside the final rules, the FCA also published Finalised Guidance for both incident reporting and third-party reporting. The FCA said that firms have 12 months to prepare before the new rules come into force on 18 March 2027. Link to PS26/2: Operational Incident and Third-party Reporting here Link to FG26/3 – Operational Incident Reporting here Link to FG26/4 – Material Third Party Reporting here Commission Report Confirms Resilience of the EU Financial Sector On 13March 2026, the European Commission (Commission) published a report on the resilience of the EU financial sector against potential disruptions. The Commission said that the assessment, which is part of the EU’s overall preparedness union strategy, confirms that Europe’s financial system is well equipped to continue providing critical services under a wide range of adverse scenarios, including geopolitical tensions, cyber incidents, natural hazards and other major disruptions. The report highlights the role of EU financial services legislation, including banking, insurance, market infrastructure and asset management frameworks, in ensuring that financial institutions and infrastructures can withstand severe shocks and continue operating. The report says that the Digital Operational Resilience Act (DORA) in particular provides a harmonised EU‑wide framework to manage ICT and cyber risks across the financial sector, including oversight of critical ICT third‑party providers. The Commission said that the report also highlights the importance of maintaining the continuity of payments and access to money as a core element of preparedness. The Commission also said that the EU has significantly reinforced its preparedness since the global financial crisis. The Commission said that the EU will keep on assessing financial sector preparedness. Where needed, the EU stands ready to swiftly trigger coordinated and proportionate EU and Member State‑level adjustments to ensure continuity in the EU financial sector’s critical functions. Link to Report on the Resilience of the EU Financial Sector here AFM: Q&A Session on the DORA Register of Information On 12 March 2026, the Dutch Authority for the Financial Markets (AFM) published Q&As following a two-hour session about the DORA register of information, where institutions were given the opportunity to ask the AFM questions about the request for information to populate the register. The questions covered topics such as the process surrounding the request, how the register should be completed, and why institutions can only submit data in xBRL-CSV this year. The AFM said the session also gave it the opportunity to understand where companies are currently experiencing the most difficulty in completing the register and what they expect from the regulator. For example, several companies wondered why so many data points are being requested and whether this could be reduced. It also became clear that companies would like to see the results of the request. As a result of the session the AFM has compiled the questions about the information register into a document. Link to Q&A From Session March 2026 here Link toWeb Page on the Register of Information DORA here