Global Trustee and Fiduciary Services Bite-Sized Issue 11 2025

11 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 • Sustainability statements: – Materiality considerations in reporting under the European Sustainability Reporting Standards (ESRS); and – Scope and structure of the sustainability statements. • ESEF digital reporting: – Common ESEF filing errors found in the Statement of Cash Flows. ESMA says that this year’s priorities reaffirm its commitment to simplification and burden reduction, while maintaining a strong focus on investor protection and market stability. In addition, ESMA says that the statement published on 14 October highlights the importance of connectivity between financial and sustainability information, recent IFRS developments, and consistent use of alternative performance measures. ESMA says that it has also published a fact-finding exercise on the 2024 corporate sustainability reporting practices by European issuers under ESRS Set 1. ESMA says this examines disclosures on the double materiality assessment process and its outcomes, providing insights on enforcement priorities and future regulatory improvements. ESMA states that issuers, auditors and supervisory bodies should consider the topics and recommendations when preparing, auditing, and supervising the 2025 annual financial reports. And adds that issuers should take the recommendations into account based on their materiality and relevance for the issuer’s operations and annual financial report. Link to European Common Enforcement Priorities here Link to Fact Finding Exercise here T+1 FCA Issue T+1 Letter to Asset Managers and Alternative Firms On 23 October 2025, the Financial Conduct Authority (FCA) published a letter (addressed to Compliance Officers) setting out its expectations for firms supervised by the FCA in the Asset Management and Alternative Firms portfolio, ahead of the upcoming market transition from a T+2 to a T+1 securities settlement cycle on 11th October 2027. In terms of what firms need to be doing, the FCA’s lists out the following expectations: • By the end of 2025, the FCA expects all firms to familiarise themselves with the recommendations in the Accelerated Settlement Task Force (AST) Final Report and put in place a project plan to move to T+1 settlement by October 2027. • The FCA encourages firms to carry out end-to end reviews of their trading, clearing and settlement arrangements. They should identify existing manual processes and blockages that could be enhanced or fixed to facilitate a faster settlement cycle. • Firms should contact their settlement agent(s) to discuss what changes they may require firms to make to settle their transactions within a T+1 settlement cycle. • Firms who outsource their relevant trading, settlement or other operational services, remain responsible for working with their outsourced providers to ensure a smooth transition to T+1 settlement. • Firms which regularly lend securities should prepare to facilitate timely recalls, including notifying as soon as possible their intermediary when they have sold securities and need to recall them to support settlement. • By the end of 2026, firms will need to have implemented the identified changes. Many of the implementation dates for the AST’s key recommendations, such as the standardisation of Standard Settlement Instructions (SSIs) and Trade Date timing for allocations and confirmations, are set for the end of 2026.