Global Trustee and Fiduciary Services Bite-Sized Issue 4 2026

25 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 FCA Regulatory Priorities – Wholesale Buy Side On 19 March 2026, the FCA published its Regulatory Priorities – Wholesale Buy Side report, one of a series of reports designed to replace more than 40 portfolio letters. The FCA aims to publish these reports annually. Set out by industry sector, the FCA says they attempt to pull together all that it is doing – whether by supervisors or in policy development. The report on the FCA’s Buy Side priorities for the next year cover: • Evolving regulation to foster growth and innovation and serve changing consumer needs – The FCA says it wants to support the UK’s status as an international investment hub. Key workstreams include its forthcoming consultation on plans for a proportionate regulatory regime for alternative investment fund managers and finalising policy work on tokenisation. – The FCA says it also aims to transform the regulatory data model for asset managers and funds to collect accurate and comparable data, enabling data-led supervision. • Delivering good outcomes to consumers – The FCA says it wants to build consumer confidence in investing and work with firms to deliver the good outcomes possible for consumers. It says it will progress its multi-firm review of model portfolio services (MPS) to assess whether investors in MPS are receiving good outcomes. It says it will also focus on outlier firms that design products and services that do not consider consumers’ best interests. • Reinforcing consistent, high standards across private market investing – Given the importance and increasing scale of private markets, it is essential that investors trust how these markets operate. Continued growth should be underpinned by good governance and responsible practices. The FCA says it is assessing standards in key areas such as management of conflicts of interest to ensure alignment with investors’ interests. Where firms offer retail access to private markets it wants to ensure they do this in a responsible way. • Preserve market integrity and resilience to disruption – The FCA says it wants to make sure that Buy Side firms continue to support well-functioning markets, even under stress; and proactively identify and manage their own vulnerabilities and emerging risks to disruption. The FCA says these are its focus areas this year. It says it will continue to monitor risks and opportunities through data, market intelligence and engagement with industry. The FCA says it will pause or stop work if it needs to look at urgent new issues. The FCA says that Buy Side firms should read both its pensions and consumer investments (see below) Regulatory Priority reports, which include complementary reforms. Link to Buy Side Priorities here Link to Pensions Priorities here CP26/8: Quarterly Consultation Paper No. 51 On 6 March 2026, the FCA published quarterly consultation paper CP26/8. In the paper, the FCA consulted on targeted changes to the Collective Investment Schemes sourcebook and the Glossary to reflect changes to the Investment Association’s revised Statement of Recommended Practice (SORP) for authorised funds. The revised SORP will be effective for annual accounting periods of authorised funds beginning on or after 1 January 2026. The closing date for comments was 13 April 2026 . Link to CP26/8 here