Global Trustee and Fiduciary Services Bite-Sized Issue 5 2026

5 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 1. Credit Stress Test; 2. Concentration Risk Analysis; 3. Reverse Stress Test; and 4. Recovery and Resolution Component. ESMA says that it will launch the data request at the beginning of May, followed by a joint validation of the submissions together with National Competent Authorities. The exercise will then proceed to the analysis and computation of results and, finally, the preparation of the report. The stress test will conclude with the publication of the final outcomes planned for the first quarter of 2027 . Link to Final Report here ESMA Releases Reporting Templates and Instructions for the Active Account Requirement On 13 April 2026, ESMA published the reporting templates and instructions for the Active Account Requirement (AAR) reporting under European Market Infrastructure Regulation (EMIR 3). The new templates set out in detail how entities subject to the AAR should report the required information to their competent authorities. Through this development, ESMA states that it aims to ensure a harmonised and efficient approach to AAR reporting across the EU, providing standardised templates and clear instructions while facilitating consistent supervisory practices. ESMA says that the first AAR reporting submission is expected on 31 July 2026, covering the period from 25 June 2025, when the AAR became applicable, to 30 June 2026. Thereafter, reporting will take place on six months basis, with submissions due on 31 January and 31 July each year, each covering a twelve‑month reference period. Link to Press Release here Link to Dutch AFM: Initial Active Account Requirement Report Must Be Received by 31 July 2026 here (17 April 2026) FINTECH FCA Sets Out Guidance to Support Innovation in Fund Tokenisation On 30 April 2026, the UK Financial Conduct Authority (FCA) published Policy Statement PS26/7 – ‘Progressing Fund Tokenisation’. The FCA says that its guidance sets out how firms can use distributed ledger technology (DLT) within the regulator’s existing rules. The FCA says that new rules will also make fund dealing more efficient, including an optional Direct to Fund (D2F) model, which will enable investors to deal directly with the fund, whether traditional or tokenised. The FCA explains that it has worked closely with industry to develop this guidance and rules to support innovation and improve efficiency for asset managers. The policy statement also sets out how fund tokenisation could develop over time as part of the FCA’s roadmap for digital assets. PS26/7 covers: • Chapter 2 : Accelerating tokenisation of authorised funds. • Chapter 3 : A new direct dealing model. • Chapter 4 : Near-term steps for fund tokenisation. • Chapter 5 : Future tokenisation models. Lastly, the FCA states that the new rules and guidance will enter force with immediate effect . Link to Policy Statement PS26/7 here