Global Trustee and Fiduciary Services Bite Sized Issue 10 2025

7 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 proposed amendments include: Adding guidance to clarify howmanagers of sustainability products that are index-tracking can meet SDR rules; • Allowing firms to prepare and publish sustainability product reports which either cover a reporting period of less than 12 months or which include a period of time during which neither a label nor specified terms were used, thereby allowing firms to align sustainability product reports with other relevant reports (e.g., TCFD reports); • Deleting ESG 5.4.8R, which requires firms to use the most recent calculation date within the 12-month reporting period; and • Removing reference to “12-month reporting periods under ESGS 5.4.8R” and clarifying that firms are not required to produce on-demand sustainability product reports until at least 16 months after the first use of a label or specified terms. The consultation period closed on 15 October 2025. Link to QCP here ESAs Note Greater Effort from Financial Market Participants in their Disclosure of Principal Adverse Impacts On 9 September 2025, the Joint Committee of the three European Supervisory Authorities (EBA, EIOPA and ESMA – the ESAs) published their fourth annual Report on the extent of voluntary disclosure of principal adverse impacts (PAIs) under the Sustainable Finance Disclosure Regulation (SFDR). The ESAs have observed a steady improvement in the quality of the PAI voluntary disclosures at both entity and product level. Like previous years, the ESAs surveyed National Competent Authorities and conducted staff- level analysis of publicly available PAI statements from the asset management, insurance and occupational pension sectors and of a sample of financial products’ PAI disclosures. The 2025 Report notes an effort from financial market participants to publish more complete information in compliance with SFDR disclosure requirements, with a general improvement in the quality of information provided. In line with previous years, the findings also confirm that financial market participants within larger multinational groups tend to provide more detailed disclosure, while smaller entities often combine general ESG or marketing information with their SFDR disclosures. SurveyedNational Competent Authorities affirmed that some financial market participants have taken onboard the good practices included in the previous reports and have improved their disclosures. Additionally, the 2025 Report also includes recommendations for National Competent Authorities to support their supervision of PAI disclosures and for the European Commission to consider ahead of the forthcoming review of the SFDR. Link to Report here HKMA Launches Public Consultation on Phase 2A Prototype of Hong Kong Taxonomy for Sustainable Finance On 8 September 2025, the Hong Kong Monetary Authority (HKMA) launched a public consultation on Phase 2A prototype of the Hong Kong Taxonomy for Sustainable Finance (Hong Kong Taxonomy). HKMA says the Hong Kong Taxonomy is an important market enabling tool for promoting informed decision-making in green and sustainable finance. By providing clear, transparent, and robust definitions of what constitutes green and sustainable activities, the taxonomy is stated as aiming to scale up relevant capital flows while addressing greenwashing concerns. Building on the publication of Phase 1 of the Hong Kong Taxonomy in May 2024, the HKMA has adopted a phased approach to further enhance the taxonomy, starting with Phase 2A, and progressing through subsequent phases.