Africa’s fiduciary services at an inflection point

Regulatory reform, market scale and rising expectations are redefining the role of trustees across the continent.

28 July 2026

6 mins

Corporate & investment bankingFinancing, Securities Services & CustodyGlobal Markets

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Africa’s fiduciary services landscape is undergoing a structural shift. As regulatory frameworks evolve and collective investment markets deepen, trustees and fiduciaries are being called on to play a more central role in safeguarding investor outcomes. Developments in South Africa, Kenya and Uganda illustrate how supervision, scale and market maturity are converging to reshape expectations across the region.

Across Africa’s investment ecosystem, fiduciary services are moving into sharper focus. Regulatory authorities are tightening supervisory frameworks, collective investment vehicles are expanding in scale and variety, and investors are demanding stronger governance and transparency. Together, these dynamics mark a clear inflection point; one that is redefining what effective fiduciary oversight looks like in African markets.

While the pace and form of change vary, developments in three markets point to a shared trajectory: a move away from narrowly rules‑based supervision toward conduct‑driven, risk‑based oversight, underpinned by rising market complexity. For trustees and asset managers alike, fiduciary capability is becoming strategic rather than ancillary.

South Africa: Conduct standards in a market of scale

South Africa provides the clearest illustration of this transition. Regulatory authorities are advancing reforms that align the country’s investment supervision more closely with international standards, including IOSCO principles. The emphasis is shifting decisively toward conduct, governance and risk management – placing greater accountability on how market participants operate and how investor interests are protected in practice.

Within the Collective Investment Schemes (CIS) sector, this evolution is reflected in the development of consolidated Conduct Standards. These are designed to replace fragmented regulatory requirements with a unified framework applying across traditional unit trusts, exchange‑traded funds, hedge funds and related structures. Although implementation is phased, the regulatory direction is unambiguous: enhanced consistency, clearer expectations and more robust oversight of fiduciary responsibilities.

This regulatory momentum coincides with a period of significant market growth. South Africa’s unit trust industry closed the year to December 2025 with assets under management of R5.68 trillion and net inflows of R196 billion – one of the strongest annual performances on record. While buoyant equity markets were an important driver, sustained inflows also point to continued confidence in regulated collective investment vehicles.

South Africa – CIS market at a glance (2025)

• R5.68tn

  Assets under management

• R196bn

  Net inflows

• 42.4%

  FTSE/JSE All Share Index total return

Source: Association for Savings and Investment South Africa (ASISA), CIS industry statistics as at 31 December 2025

Importantly, flows have been concentrated in multi‑asset income, interest‑bearing short‑term and higher‑equity strategies – segments that tend to involve more nuanced risk profiles and portfolio construction. In this context, trustees are expected not only to oversee compliance but also to ensure that fund structures, mandates and controls remain aligned with stated investment objectives and investor expectations.

Kenya: Rapid expansion meets regulatory strengthening

Kenya’s collective investment market presents a different, but equally compelling, picture. Over the past five years, assets under custody have grown sharply, accompanied by a marked increase in the number and variety of schemes. Product innovation- including special funds, foreign‑currency‑denominated offerings and offshore exposure- has broadened the investment landscape.

This expansion has been matched by a clear regulatory response. The introduction of trustee licensing requirements, standardised reporting templates and fit‑and‑proper criteria for key personnel reflects a maturing supervisory approach. These measures are intended to reinforce fiduciary accountability as the market scales, ensuring that growth is underpinned by appropriate governance and transparency.

Kenya – market growth indicators

Source: Capital Markets Authority (Kenya), CIS Quarterly Reports (2018–2025)

For fiduciary service providers, Kenya’s experience highlights the importance of scalability and regulatory engagement. As cross‑border exposure and alternative allocations increase, trustees are being called on to support more complex asset structures – requiring enhanced reporting, robust controls and a deeper understanding of evolving regulatory expectations.

Uganda: Expanding the fiduciary perimeter

In Uganda, regulatory change is broadening the scope of fiduciary involvement beyond traditional collective investments. Recent updates now require the appointment of intermediaries, including trustees, for certain securities issuances such as private placements and corporate bonds. While not universal across all instruments, the change signals a deliberate effort to strengthen governance safeguards within capital market activity.

This shift coincides with the evolution of Uganda’s wealth management landscape. New asset managers are entering the market, while commercial banks are expanding custody and investment services as part of broader retail wealth propositions. As custody, distribution and product manufacture converge, fiduciary requirements are extending into new structures, including note trustee arrangements and bespoke investment vehicles.

At the same time, ongoing professional development has become a formal component of licence renewal for approved persons, reinforcing regulatory expectations around technical competence and continuous capability‑building.

A common direction of travel

Across these markets, a clear regional pattern is emerging. Regulatory authorities are raising the bar for fiduciary conduct, insisting on stronger governance and clearer accountability. Markets are growing not just in size, but in sophistication. Investors, in turn, are relying more heavily on trustees to function as a stabilising force – supporting confidence in rapidly evolving investment environments.

For fiduciary service providers, this represents both responsibility and opportunity. Those able to combine regulatory insight, operational resilience and scalable fiduciary expertise will be well positioned to support Africa’s next phase of capital market development.

Across jurisdictions, fiduciary expectations are also evolving in how trustees engage. Effective fiduciary oversight increasingly requires a collaborative approach – working closely with clients and maintaining constructive dialogue with regulators.

Trustees are uniquely positioned to act as a conduit between the commercial objectives of collective investment schemes and the integrity of regulatory frameworks, supporting product innovation and growth while ensuring adherence to conduct and governance standards. In this context, the trustee’s role extends beyond policing compliance to enabling sustainable market outcomes through informed judgement, balance and engagement.