Global Trustee and Fiduciary Services Bite-Sized Issue 7 2026

20 AI CRYPTOASSETS CYBER DORA IOSCO MONEY MARKET FUNDS SUSTAINABLE FINANCE/ESG ASIA PACIFIC AUSTRALIA EUROPE IRELAND LUXEMBOURG NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 7 | 2026 Quick Links FCA Consults on Consumer Duty – Scope and Proportionality On 29 June 2026, the FCA published a Consultation Paper on ‘Consumer Duty – Scope and Proportionality’ (CP26/23). The FCA says that the changes are part of its plans to give wholesale firms the confidence to apply the Consumer Duty proportionately. The FCA explains that it is consulting on a targeted package of changes to its rules and non- Handbook guidance to: • Remove business with non-UK customers from the Consumer Duty’s scope; • Make it clearer where the Consumer Duty applies and where it does not; • Clarify when and how firms can rely on each other when they work together in distribution chains, and how they can apply the Consumer Duty more proportionately; and • Explain the interaction between the Consumer Duty and other product governance rules. The FCA says that its changes are intended to clarify when the Consumer Duty applies – and when it does not – to give firms greater confidence in its scope. The FCA adds that they also promote a more proportionate approach based on a firm’s role, helping reduce unnecessary cost and complexity while preserving strong protections for retail customers. Comments are due by 18 September 2026 . Link to CP26/23 here Link to ‘Refining the Consumer Duty to give greater confidence to wholesale firms’ – Simon Walls, Executive Director of Markets, FCA here FCA Consults on Targeted Changes to Listing Rules for Closed-ended Investment Funds On 26 June 2026, the FCA published a consultation paper on proposed changes to its UK Listing Rules for closed‑ended investment funds, focused on the management of conflicts of interest. The review, announced in March 2026 as part of the FCA’s ongoing work on the UK Listing Rules, considers how its rules support strong shareholder rights and effective management of conflicts of interest in a range of potential future scenarios. As part of good regulatory practice, the FCA explains that it has been stress testing how the rules would operate in different hypothetical situations to ensure they remain robust over time and as markets evolve. The FCA says that this has included exploring a range of plausible scenarios to test whether the FCA’s conflicts of interest framework would operate consistently in future. As a result of this work, the FCA states that it has identified a small number of targeted and proportionate adjustments to ensure its rules continue to apply consistently in all relevant scenarios. Specifically, they aim to: • Ensure the same protections that apply to arrangements with an existing investment manager also apply when a newmanager is being appointed, to ensure consistent protections for all changes to investment manager fees and strategies; • Recognise the association between a director and a substantial shareholder that proposed them for a board appointment, to strengthen the integrity of boards acting independently of any investment manager; and • Recognise the conflict arising where a substantial shareholder is also an investment manager and votes on material changes to investment policies, to ensure that the rights of minority shareholders are appropriately protected. The FCA says that it believes these changes are important given the central role of the investment management contract in shaping outcomes for shareholders. The FCA also says that it welcomes views on whether these proposals strike the right balance by 14 August 2026 and aims to finalise rules before the end of the year. Alongside this consultation, the FCA has also published examples of good practice to support retail investors in exercising their voting rights, as part of its broader work to promote effective shareholder engagement. Link to Consultation Paper here Link to Good Practice Guidance here