Global Trustee and Fiduciary Services Bite-Sized Issue 9 2026

6 AI CRYPTOASSETS EMIR FINTECH FUND LIQUIDITY OPERATIONAL RESILIENCE RETAIL INVESTMENT STRATEGY T+1 ASIA PACIFIC AUSTRALIA EUROPE NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 9 | 2026 Quick Links OPERATIONAL RESILIENCE Dutch AFM Publishes DORA Update 7 On 6 August 2026, the Dutch Authority for the Financial Markets (AFM) published its Digital Operational Resilience Act (DORA) Update 7. The AFM says that the financial sector has made major progress since the introduction of DORA, but at the same time, as a result of its supervision and requests for information, the AFM has identified areas requiring further action from financial companies. In its DORA Update 7, the AFM summarises the key developments: • Strong improvement in input for information registers of information . The AFM says that the number of registers approved by the European Banking Authority rose from 40% in 2025 to 94% in 2026. The AFM states that it suspects this is because firms now have a better understanding of how to enter information in the register and how the required format works. Nevertheless, they must continue paying attention to the quality of the register and the underlying data, to ensure that future requests for information can be processed smoothly and efficiently. • Vigilance with regard to procedures and policies . The AFM also calls on firms to assess at regular intervals whether their organisation remains fully compliant with the DORA requirements. The AFM explains that supervisory reviews show that not all firms have all the required policy documents and procedures, or that these do not comply fully with the regulations. The AFM says that firms should therefore check whether their Information and Communications Technology risk management, policies, and procedures are up to date and reflect day-to-day practice. The AFM adds that firms that use policies and procedures drawn up at group level must check for themselves whether all relevant DORA requirements have been fully incorporated into those documents and procedures. This is because the financial entity subject to DORA (licensee) remains responsible at all times for compliance with the DORA requirements. • Number of incident reports lower than expected . The AFM says that another area requiring attention is the incident process. The number of DORA incident reports received has been lower than expected. Firms must ensure that incidents are promptly detected, classified and, where required, reported within the statutory time limits. • Clarity concerning insurance intermediaries . Finally, the AFM says the European Supervisory Authorities provided more clarity regarding the method to be used to calculate thresholds where insurance intermediaries have a very limited activity dedicated to the insurance business. The AFM says that there is now also greater clarity with regard to the calculation of thresholds within group structures. Firms should therefore check whether the recent Q&As have implications for their organisation. Link to AFMDORA Update 7 here