Global Trustee and Fiduciary Services Bite-Sized Issue 5 2026

18 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 FCA Blog: Year 2 Consumer Duty Board Reports: Progress andWhat Comes Next On 16 April 2026, Jonathan Pearson, the Head of Consumer Policy at FCA, published a Blog Post on ‘Year 2 Consumer Duty Board Reports: Progress and What Comes Next’, explaining that Consumer Duty Board reports help turn governance into real change and better outcomes for consumers. Adding that firms have improved, but more progress is needed. He adds that good Consumer Duty Board reports provide clear evidence about outcomes – helping to turn governance into real change. Boards can ask better questions, hold people to account, and act quickly to make sure they are not causing harm or offering poor value. He adds that the FCA have seen this lead firms to design better products, communicate more clearly and support their customers better. Which means they fix issues sooner, and customers are more likely to get fair value and the help they need, and with the third cycle of Consumer Duty Board reports on the horizon, now is a good moment to pause and reflect on what has been learned from year 2. Comparing year 1 and 2 reports – what’s improved • Stronger governance and clearer Board oversight; • Better action plans and ownership; and • Broader and more insightful data. Where firms need to do more While the year 2 reports show progress, Pearson says that the FCA still found that the quality and depth of analysis was variable. Firms should focus on the following areas in the year ahead: • Clearly link data to customer outcomes; • Monitor outcomes delivered by third parties; • Evidence meaningful Board challenge; and • Deepen assessment of consumer understanding and support. Looking ahead, Pearson says that the improvements the FCA have seen show that firms continue to move in the right direction. He says that the FCA wants firms to draw on these insights as they approach their 3rd year submissions and that firms should continue strengthening their outcome monitoring, governance and distribution oversight so that the Consumer Duty continues to deliver good outcomes for consumers. Link to FCA Blog here FCA: Asset Management: Improving Applications for Authorisation On 9 April 2026, to help firms apply for authorisation, the FCA published a non-exhaustive list of common issues with applications which have reduced firms’ chances of success or caused delays. For each of the following areas, the FCA sets out what it wants to see, areas of good practice and areas for improvement: • Office location: location of mind and management; • Outsourcing: underestimating accountability; • Business models: exposing clients to risk; • Conflicts of interest: failing to identify concerns; • Understanding the regulatory status of clients; • Redress: Ensuring clients have access to appropriate schemes that protect consumers; • Changes to the scope of permissions; and • Fund particulars and mandates.