Global Trustee and Fiduciary Services Bite-Sized Issue 4 2026

4 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 EMIR The EBA Consults on Regulatory Products on Initial Margin Model Authorisation On 17 March 2026, the European Banking Authority (EBA) launched two public consultations on draft Guidelines and draft Regulatory Technical Standards (RTS) on initial margin model authorisation (IMMA) under the European Market Infrastructure Regulation (EMIR). The EBA said that these consultations mark an important step in ensuring that models used for the exchange of initial margin for non-centrally cleared derivatives are subject to a robust, efficient and harmonised authorisation process across the European Union (EU). Under the new EMIR 3 rules, counterparties using internal initial margin models must obtain prior authorisation from their competent authority (CA). The EBA said that the draft Guidelines and RTS aim to support a transparent, predictable, and consistent approach to model assessment and authorisation throughout the EU. The draft Guidelines specify the minimum information and documentation that counterparties must submit for their application to be considered complete. These requirements build on the information already outlined in the Annex to the EBA’s No Action Letter on the application of EMIR, published in December 2024, which will cease to apply once the new Guidelines enter into force. The draft RTS set out the assessment techniques that CAs will apply when authorising initial margin models. They only apply to counterparties belonging to groups with an aggregate monthly average notional amount (AANA) of non-centrally cleared over-the-counter (OTC) derivatives exceeding EUR 750 billion. Where an internal model relies on a pro-forma model, it must be validated by the EBA prior to authorisation by the CA. The deadline for the submission of comments is 17 June 2026 . Link to Consultation Paper on Draft Guidelines here Link to Consultation Paper on Draft RTS here FINTECH The Future of Agentic AI On 31 March 2026, the Digital Regulation Cooperation Forum (DRCF) published a ‘Foresight Paper’ detailing DRCF’s forward-looking exploration of agentic AI and how UK regulatory frameworks can help realise the opportunities of this technology in a responsible and safe way. In the paper the DRCF emphasises that regulation should act as an enabler of innovation, ensuring that emerging technologies develop in ways that promote economic growth and competition while protecting consumers and their rights. The DRCF says the paper aims to foster debate and discussion among its stakeholders. Link to The Future of Agentic AI: Foresight Paper here Smart Data Strategy On 26 March 2026, the UK government’s Department for Business and Trade (DBT) published Smart Data 2035: The UK’s Smart Data Strategy. This paper sets out the UK government’s next steps to develop a smart data economy in the UK, following the introduction of the Data (Use and Access) Act 2025. It discusses the potential for schemes that maximise benefits for customers across the economy and that work well with one another and with the UK’s wider data ecosystem, including artificial intelligence (AI). In respect of financial services, the paper discusses the potential benefits of Open Finance including: • Financial Wellbeing : focusing on improving financial health through personalised credit scoring, debt management, and predictive tools, drawing on data such as credit reports, savings, pensions, and investments;