Global Trustee and Fiduciary Services Bite-Sized Issue 11 2025

10 QUICK LINKS AIFMD CBDC CRYPTOASSETS DIGITAL ASSETS FINTECH FSB MIFID/MIFIR (UK) IFR/IFD OPERATIONAL RESILIENCE OUTSOURCING SUSTAINABLE FINANCE/ESG T+1 TOKENISATION ASIA PACIFIC EUROPE NETHERLANDS NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 11 | 2025 Project Symbiosis: AI and Big Data Technologies for Supply Chain Sustainability Disclosure On 17 October 2025, Bank for International Settlements (BIS) published a report on Project Symbiosis, a collaboration between the BIS Innovation Hub Hong Kong Centre and the Hong Kong Monetary Authority (HKMA), which BIS says used cutting-edge technology to develop new ways for companies to track and disclose the environmental impact of their activities and those of their suppliers. BIS says that it showed that artificial intelligence (AI) and related technology approaches can help improve the speed, breadth and quality of data collection, and generate intelligent environmental impact results that are flexible with respect to a wide range of data availability scenarios. It can also highlight financeable emission reduction opportunities. BIS also says that the lessons of Project Symbiosis, while applied in the context of Scope 3 reporting, are of broader significance, illustrating how AI and related technologies may be applied in a range of contexts such as risk assessment, supply chain management, and reporting automation as its rapid evolution continues. Link to Report Webpage here ESMA Publishes Final Report on RTS on the Transparency and Integrity of ESG Rating Activities On 15 October 2025, the European Securities and Markets Authority (ESMA) published Technical Standards under the Regulation on the transparency and integrity of Environmental, Social and Governance (ESG) rating activities (Final Report). ESMA launched a public consultation on these draft regulatory technical standards (RTS) in May 2025. The public consultation closed on 20 June. In the Final Report ESMA says that it has revised the three RTS to take into account the feedback received to the public consultation. For the RTS on authorisation and recognition ESMA says this has involved the removal or simplification of a number of information requirements. For the RTS on separation of business, ESMA says that the requirement for a physical separation of staff remains, however other requirements such as requirements for network segmentation have been clarified or removed when it was judged to be imposing excessive burden. And for the RTS on Disclosures, ESMA says that a number of elements have been revised to ensure they are practically achievable by ESG rating providers, while others have been removed when it was judged they did not provide sufficient added value for the burden that was imposed. ESMA has submitted the draft technical standards to the European Commission for adoption by means of a Commission Delegated Regulation (for RTS). ESMA also notes that the technical standards will also be subject to non-objection by the European Parliament and Council. The draft Delegated Regulations will enter into force 20 days after they are published in the Official Journal and will apply from 2 July 2026. Link to Final Report here ESMA Announces 2025 European Common Enforcement Priorities and Results of Fact-finding on Materiality Considerations in Sustainability Reporting On 14 October 2025, ESMA outlined the European Common Enforcement Priorities (ECEP) for the 2025 annual financial reports of listed issuers. ESMA asks issuers to focus on the following areas in their 2025 annual financial reports, in addition to general considerations: • IFRS financial statements: – Geopolitical risks and uncertainties; and – Segment reporting.