Global Trustee and Fiduciary Services Bite-Sized Issue 11 2025

15 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 In parallel, the SFC says that it has streamlined the authorisation process and documentary requirements for REITs, taking into account the latest updates under the Rules Governing the Listing of Securities on The Stock Exchange of Hong Kong Limited (SEHK) and market practices. Under the streamlined process, the SFC anticipates that a new REIT authorisation application c an be decided on within four weeks from take-up under normal circumstances. Further, to facilitate secondary offerings of existing SFC-authorised REITs, the SFC says that a circular was also issued to REIT managers on 13 October, setting out certain streamlined documentary requirements. The SFC explains that prospective REIT applicants and their professional advisers are welcome to contact the SFC through the REIT Channel via email at REIT_Channel@sfc.hk on their proposals. Link to SFC Announcement here Link to Circular here EUROPE Cyber Risk and Digital Resilience Will Drive the Agenda of ESMA’s Union Strategic Supervisory Priorities for 2026 On 24 October 2025, the European Securities and Markets Authority (ESMA), welcomed the strong initial engagement by National Competent Authorities (NCAs) on cyber risk and digital resilience and calls for continued efforts on the Union Strategic Supervisory Priorities (USSPs). ESMA says that it promoted cyber and digital resilience as a strategic supervisory priority of the European Union (EU) starting January 2025 in direct alignment with the entry into application of the Digital Operational Resilience Act (DORA). ESMA states that this allows enhanced coordination of EU supervisors’ efforts toward strengthening firms’ ICT risk management and improves the digital resilience of the EU securities market. Since the start of this USSP, ESMA says that NCAs and its direct supervision have demonstrated commitment to monitor financial entities’ adherence to DORA requirements through proactive checks and supervisory capacity building. Given the importance of securing a resilient financial sector, ESMA is calling on NCAs to keep up their efforts in 2026 to continue ensuring effective supervisory implementation across the EU. ESMA also says that through 2025, it and NCAs have carried out intense supervisory work on ESG disclosures, defined as a USSP since 2022. This has played a pivotal role in promoting the application of ESG requirements throughout the sustainable investment ecosystem, guiding and supporting market participants on this journey. In 2026, ESMA says that NCAs will target efforts to consolidate achievements under the ESG disclosures USSP, focusing on high-risk areas. Link to ESMA Announcement here Commission Unveils 2026Work Programme On 21 October 2025, the European Commission (Commission) unveiled its 2026 Work Programme, which outlines a series of actions to help build a more sovereign and independent Europe. The Commission says that the Work Programme, entitled ‘Europe’s independence moment’, addresses current and future challenges arising from threats to Europe’s security and democracy, to conflicts and geopolitical tensions, to risks to its economy and industry, and accelerating climate change. The Commission says that the Work Programme doubles down on its current core priorities by aiming to strengthen competitiveness, lead in clean and digital innovation, strengthen the EU’s unique social model and ensure collective security. With simplification and implementation as a focus, the Commission says that in 2026 it will continue to cut red tape for people, business and administrations.