Global Trustee and Fiduciary Services Bite Sized Issue 10 2025

4 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 The Occasional Paper is divided into five sections: • Section 1 – Introduction; • Section 2 – MRM and explainability: Discusses MRM requirements that may be affected by lack of AI explainability; • Section 3 – Challenges in enforcing explainability requirements in the context of AI: Outlines the different AI explainability methodologies and their limitations, and the challenges of implementing them in the context of more complex AI models; • Section 4 – Potential adjustments to MRM guidelines: Describes potential adjustments to existing MRM requirements to address these challenges; and • Section 5 – Conclusion. Link to Occasion Paper No.24 here MIFID II/MIFIR ESMA Provides Updated Instructions for Weekly Commodity Derivative Position Reporting On 25 September 2025, the European Securities and Markets Authority (ESMA) published updated reporting instructions and XML schema (version 1.2.0) for the weekly reporting of commodity derivatives positions under the Markets in Financial Instruments Directive II (MiFID II), reflecting the changes from the latest review. Beyond the changes directly originating fromMiFID II – such as the requirement to publish two weekly reports and the exclusion of (spot) emission allowances from position reporting – the updated XML schema and reporting instructions also include other amendments to ITS 4, like the harmonisation of reporting units for energy derivatives. The adjustments are based on ESMA’s Final Report submitted to the European Commission in December 2024, which is currently pending adoption. ESMA has opted for this approach to ensure a consistent reporting framework and minimise the need for frequent updates to the XML schema and instructions. ESMA will start applying the new XML schema and reporting instructions on 1 April 2026. As of that date, reporting entities should only use the latest version 1.2.0. Link to Reporting Instructions here Link to XML Schema here OPEN FINANCE FCAWebpage: Smart Data Accelerator On 22 September 2025, the Financial Conduct Authority (FCA) launched a webpage detailing its Smart Data Accelerator (the Accelerator). The FCA says that the Accelerator aims to advance open finance and smart data for businesses in the UK. The FCA says the Accelerator offers a secure, dedicated space for research, testing, and experimentation, enabling organisations to use synthetic data to develop proofs of concept while supporting agile, dynamic policy making. The Accelerator is comprised of four pillars: • Use case testing; • Policy testing;