Global Trustee and Fiduciary Services Bite Sized Issue 10 2025

6 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 ASIC Publishes FAQs on Auditing and Assurance Requirements for Sustainability Reports On 16 September 2025, the Australian Securities & Investments Commission (ASIC) published responses to frequently asked questions (FAQs) about the review and auditing requirements for sustainability reports under the Corporations Act 2001 . ASIC says the FAQs may be helpful for: • Auditors in understanding their obligations under the Corporations Act, such as in relation to forming an opinion on the sustainability report, what the auditor’s report on the sustainability report must contain, and the extent to which the modified liability settings apply to statements in the auditor’s report on the sustainability report, and • Preparers of sustainability reports in understanding their obligations in relation to obtaining a review or audit of the sustainability report, the appointment, removal or resignation of auditors, and who can conduct a review or audit of the sustainability report. ASIC says it will take a pragmatic and proportionate approach to supervision and enforcement as the review and auditing requirements for sustainability reports under the Corporations Act are being phased in. ASIC says it is more likely to commence an enforcement investigation where it sees misconduct of a serious or reckless nature. Link to FAQs here DNB Publishes Updated Guide on Climate and Nature-related Risks On 10 September 2025, De Nederlandsche Bank (DNB) published an updated guide to help financial institutions strengthen their approach to climate and nature-related risks. DNB says the updated guide includes new practical examples, such as how to manage nature risks and how to integrate climate action plans into risk management. DNB states that, by law, financial institutions are required to manage all material risks, including ESG risks such as climate and nature-related risks. While many institutions have taken steps to incorporate these risks into their risk frameworks, previous assessments by DNB show that integration is not yet consistent across the sector. DNB says the updated guide offers additional tools and examples to help institutions better identify, assess, and manage these risks. These resources are meant to inspire institutions in shaping their own approach to meeting statutory requirements. DNB notes that recent years have seen major developments in both regulation and understanding of climate and nature-related risks. The updated guide reflects these changes and includes: • Expanded statutory frameworks; • New insights into nature-related and legal sustainability risks; and • Updated good practices, including examples of nature risk management and the role of climate action plans. DNB says that it uses the guide’s focal points in its supervision of financial and non-financial risks related to climate change and environmental degradation. This supervision will follow a risk-based approach, tailored to the institution’s size, complexity, and the materiality of the risks. Link to Guide here FCA Proposes Minor Amendments to SDR On 10 September 2025, the Financial Conduct Authority (FCA) published a Quarterly Consultation Paper (CP25/24), which included proposals to make amendments to the Environmental, Social and Governance sourcebook (ESG) for the purposes of giving proper effect to an existing rule and amending rules to give firms more flexibility in relation to the publication of Part B of a public product-level sustainability report. The FCA says these minor amendments are consistent with the policy proposals consulted upon in Consultation Paper CP22/20 (Sustainability Disclosure Requirements (SDR) and investment labels) and finalised in Policy Statement (PS23/16).