Global Trustee and Fiduciary Services Bite-Sized Issue 6 2026

22 AIFMD CRYPTOASSETS FINTECH FSB IOSCO MIFID II/MIFIR MONEY MARKET FUNDS OPERATIONAL RESILIENCE SUSTAINABLE FINANCE/ESG T+1 ASIA PACIFIC EUROPE LUXEMBOURG NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 6 | 2026 Quick LInks • Allow depositaries to delegate the relevant safekeeping function for ‘non-custodial’ private market asset types (including real estate) to the AFM’s affiliates, subject to additional protections for the fund where this is done; • Clarify elements of the authorised fund registration function requirements; • Clarify how the CASS 6 custody rules apply to depositaries of all authorised funds and unauthorised AIFs; and • Replace the Modification by Consent for COLL 5.6.22R (in respect of COLL 5.5.9R, on guarantees and indemnities) with a permanent rule change. The consultation period closes on 9 July 2026 . Link to CP 26/16 here Regulatory Initiatives Grid On 19 May 2026, the Financial Services Regulatory Forum published the tenth edition of the regulatory initiatives grid which sets out the UK’s regulatory pipeline. Investment management specific initiatives include: • Solo remuneration rules review – engagement expected during Q3 2026 ; • Liquidity risk management in funds – consultation on retail funds investing in illiquid assets expected during H2 2026 ; • Improving Money Market Fund resilience as part of UK commitment to Financial Stability Board (FSB) 2021 review of March 2020 Dash for Cash – guidance, rules and HM Treasury engagement expected H2 2026 ; • Review of data collection for asset managers and funds – Consultation on draft rules expected Q3 2026 ; • Registration of authorised fund assets – consultation published 21 May 2026 (see above); and • Repeal and replace of the Alternative Investment Fund Managers Directive (AIFMD), making it more streamlined and tailored to UK markets – HM Treasury and FCA engagement due mid-2026 . Link to the Grid here Financial Services Growth and Competitiveness Strategy Regulatory Environment – Cross- Cutting Reforms Consultation Response On 12May 2026, HMTreasury published a summary of the key themes raised by respondents in response to the questions in its July 2025 consultation on ensuring the financial services regulatory environment is effective, proportionate, and in line with the government’s ambition on regulation, and notes the UK Government’s final policy position on the proposals within the consultation. Having considered the feedback received, the government says it intends to legislate to: • Set new, shorter statutory deadlines for determining applications for new firm authorisations, variations of permissions, and senior manager approvals. • Require the FCA and PRA to produce new long-term strategies, at least once every 5 years. • Require the regulators to have regard to regulatory and supervisory principles, as well as remit letters (containing recommendations fromHM Treasury) when producing their new long-term strategies, and remove the requirement for the regulators to consider these when making day- to-day decisions. • Remove a range of reporting and other procedural requirements from the regulators which are of lower value to stakeholders.