Global Trustee and Fiduciary Services Bite Sized Issue 10 2025

13 QUICK LINKS FINTECH MIFID II/MIFIR OPEN FINANCE SUSTAINABLE FINANCE/ESG T+1 ASIA AUSTRALIA EUROPE NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 10 | 2025 ESMA says its activities will remain closely aligned with the agenda of the European Commission and co-legislators, maintaining the agility needed to address evolving regulatory, economic, and technological landscapes. Beyond the priorities coming from the SIU strategy, ESMA says it will continue supporting implementation of key legislative files agreed under the previous legislature, notably the European Market Infrastructure Regulation (EMIR 3) and the European Single Access Point (ESAP). ESMA notes other ongoing legislative files which, depending on progress, may require its attention in 2026 including the Retail Investment Strategy (RIS), as well as the review of the PRIIPS, SFDR and Securitisation Regulation. ESMA says that it will ensure that it integrates the principles of Simplification and Burden Reduction across all its activities and will follow up on the 2025 ‘flagship’ projects seeking simplification and efficiencies in disclosure and reporting frameworks. Regarding ESMA’s work on data innovation and market integration, its says that it will focus on enhancing data capabilities and promoting innovation across the EU financial sector. Key projects for 2026 include the rollout of the ESMA Data Platform, centralisation studies, and the development of AI-powered supervisory tools. ESMA says these initiatives will bring common benefits to both it and the National Competent Authorities, improving market efficiency and transparency through the support that data provides for risk-based and data-driven supervision across Europe. In the digital finance sector ESMA says it will continue to focus on the effective implementation of MiCA, as it is key to ensuring investor protection and the orderly functioning of crypto-asset markets. ESMA’s supervisory convergence efforts will remain focused notably on the authorisation and supervision of CASPs. Finally, in line with the EU’s ambition to accelerate the settlement cycle to T+1 by 11 October 2027, ESMA says it will also coordinate closely with market participants to ensure the smooth transition and preparedness of the financial sector for this event. Link to 2026 Annual Work Programme here ESA’s Publish Autumn 2025 Joint Committee Report on Risks and Vulnerabilities in the EU Financial System On 19 September 2025, the European Supervisory Authorities (EBA, EIOPA and ESMA – ESAs) issued their Autumn 2025 Joint Committee Report on risks and vulnerabilities in the EU financial system. The Report highlights how tensions in global trade and the global security architecture have deepened geopolitical uncertainties. The ESAs call for increased vigilance and urge financial entities to “maintain adequate provisions in today’s tense and unpredictable environment.” In the Report, the ESAs advise national supervisors, financial institutions andmarket participants to: • Continue embedding geopolitical risks in their day-to-day business operations and risk assessments, including their dependencies on non-EUmarkets and service providers; • Prepare for short- and medium-term challenges amid high uncertainties, such as market corrections, by maintaining adequate provisions and stress testing their liquidity positions; • Strengthen vigilance against cyber risks and their potential impact on operational and financial stability, also via third-party service providers; • Monitor contagion risks from crypto assets as the market expands and interlinkages between crypto markets and the traditional financial sectors deepen; and • Play an active role in supporting the Savings and Investments Union (SIU) initiative while duly considering the liquidity characteristics and risk profiles of alternative investments and their suitability for retail investors. Link to the Report here