Global Trustee and Fiduciary Services Bite-Sized Issue 8 2026

AIFMD The UK AIFMRegime On 14 July 2026, the Financial Conduct Authority (FCA) and HMT Treasury published consultations detailing their plans for the transfer of the on shored AIFMD and Regulation from primary legislation to the FCA Handbook, including proposals that cover: • The introduction of a new sourcebook, the Alternative Investment Funds sourcebook (ALTS), to bring most of the AIFM rules (excluding those for authorised funds that would remain in the Collective Investment Schemes sourcebook (COLL)), and the deletion of the Investment Funds sourcebook (FUND); • Proposals to change the current AIFM categorisations from full-scope, small authorised, and small registered AIFMs to a simpler regime based around core rules for all AIFMs, with escalating requirements as firms increase in size (based on AUM) from small (<= GBP 750m AUM) through to medium (>= GBP 750mn to GBP 5bn AUM), to large (>= GBP 5bn AUM); • Amending the AIF definition in legislation, to clarify grey areas that have led to different interpretations of the definition of an AIF; • Changes to valuation requirements, including proposals to remove statutory provisions relating to external valuers; • Leverage calculations; • Risk management; • Liquidity risk management; • Delegation; • Annual reporting to investors; • Investor disclosures; • Closed-ended investment funds trading on UK markets and internally managed investment companies; and • National Private Placement Regime and cross-border marketing. In addition to the proposed rule changes, the FCA’s consultation paper includes discussion chapters covering the role of depositaries and prime brokers, the application of the AIFM business restriction, and a review of the prudential regime for fund managers including UCITS management companies and residual CIS operators. The FCA says it aims to publish a second consultation paper on any remaining areas of the AIFM regime, including areas covered by the discussion chapters. Investor Services Bite-Sized Global Trustee and Fiduciary Services Quick Links Issue 8 | 2026 AIFMD CRYPTOASSETS EMIR FINTECH IOSCO MIFID II/MIFIR OPERATIONAL RESILIENCE SUSTAINABLE FINANCE/ESG T+1 ASIA PACIFIC EUROPE NORTH AMERICA UNITED KINGDOM