Global Trustee and Fiduciary Services Bite-Sized Issue 5 2026

17 QUICK LINKS AI CRYPTOASSETS CYBER EMIR FINTECH FUND LIQUIDITY MICA SUSTAINABLE FINANCE/ESG T+1 ASIA PACIFIC EUROPE IRELAND NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 5 | 2026 The FCA says that removing these requirements would simplify the IPO process and improve the conditions for listing in the UK. This would support the FCA’s work to strengthen the UK’s capital markets and to support growth and competitiveness. The FCA states that no other rule changes are proposed at this stage. However, the consultation paper includes discussion questions on whether further reform of the 2018 IPO information flow rules may be appropriate. The FCA welcomes feedback by 29 May 2026 . Link to Consultation here FCA and PRA ConfirmChanges to Streamline Senior Manager Accountability and Boost Growth On 22 April 2026, the FCA and Prudential Regulation Authority (PRA) published policy statements on the Senior Managers and Certification Regime (SM&CR). The changes, which the FCA says come as the first phase of a multi-stage package of reform from the Government and regulators, will maintain the core principle of senior leader accountability, and will benefit firms by: • Giving more time to submit senior manager applications when there has been an unexpected or temporary change; • Removing the need to certify people to hold multiple overlapping functions, which will reduce the total number of certification roles required by around 15%; • Helping to streamline annual checks to certify individuals as ‘fit and proper’; • Making only larger, more complex firms meet enhanced standards, by raising many of the enhanced firm thresholds by 30%; • Helping to better understand the definition of certain senior management roles; • Allowing more time to report updates to senior manager responsibilities; • Increasing how long criminal record checks for senior manager applications are valid for, prior to application submission; and • Giving more time to update the directory, which lists certified staff. The FCA states that the Government’s further changes to SM&CR, published in its consultation response on 22 April 2026, follow its consultation in 2025. Proposals include removing the Certification Regime, which applies to less senior roles, from legislation. The Government also proposes giving more flexibility to the regulators to further reduce the number of senior management functions (SMFs) which require pre-approval. Next steps The FCA says that most changes took effect on 24 April 2026 , so firms can benefit from them straight away and adds that improvements to regulatory reporting and processes will apply from 10 July 2026 . The FCA explains that this gives firms and the FCA time to make changes to processes and procedures. Lastly, the FCA says that changes made to align with PS25/23: ‘Tackling non-financial misconduct in financial services’ , will apply from 1 September 2026 . Link to FCA PS26/6: Senior Managers and Certification Regime Review here Link to PRA PS12/26 – Review of the Senior Managers and Certification Regime − Phase 1 here