Global Trustee and Fiduciary Services Bite-Sized Issue 8 2026

21 AIFMD CRYPTOASSETS EMIR FINTECH IOSCO MIFID II/MIFIR OPERATIONAL RESILIENCE SUSTAINABLE FINANCE/ESG T+1 ASIA PACIFIC EUROPE NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 8 | 2026 Quick Links • Third country AIFMs marketing in the UK under the National Private Placement Regime (NPPR): unauthorised AIF(s) marketed in the UK. • Operators of recognised schemes: Overseas Fund Regime (OFR) and s.272 individually recognised overseas schemes. • Some MiFID investment managers and advisers, including collective portfolio management investment firms. • Operators of collective investment schemes. The FCA also says it is exploring whether some aspects of reporting could be introduced earlier, depending on firm readiness. Consultation period closes: 22 September 2026 FCA to produce further prototype forms: Before the end of 2026 Policy Statement: First half 2027 Implementation of final regime: Aim – full implementation in 2028 Link to Consultation CP 26/26 here CP26/27: Remuneration: Solo-regulated Firms’ Rules Reform On 14 July 2026, the FCA published a consultation seeking views on proposals for a simpler, more proportionate remuneration regime for in-scope FCA solo-regulated firms. Currently the remuneration framework applies across FCA solo-regulated firms: • Alternative investment fund managers (AIFM) (SYSC 19B); • UCITS management companies (UCITS) (SYSC 19E); and • MIFIDPRU investment firms (SYSC 19G). The FCA says that feedback from firms suggests the rules are difficult to apply and may impose unnecessary burden, particularly for firms that do not pose systemic risk. To remove duplication, improve clarity and reduce complexity for firms, the FCA’s proposals include replacing the 3 existing remuneration codes with a single consolidated code for in-scope solo- regulated firms. The FCA says it proposes to move from detailed, prescriptive rules towards a more outcomes- focused approach based on firm governance and accountability. The consultation applies to: • Investment firms; • Alternative investment fund managers; • UCITS (Undertakings for Collective Investment in Transferable Securities) management companies; and • Firms in the same group as at least 1 of the types of firms in the 3 categories above. The consultation period closes on 16 September 2026 . FCA aims to publish a policy statement: In Q1 2027 New rules and guidance: Come into force immediately Exception: Changes relating to AIFMs: Tied into the broader AIFM reforms (see above) Link to Consultation CP 26/27 here