Global Trustee and Fiduciary Services Bite-Sized Issue 11 2025

16 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 The first overview report on simplification, implementation and enforcement, which was also adopted on 21 October, highlights the progress achieved so far – such as the six omnibus packages and other simplification proposals aiming to bring over EUR8.6 billion in annual cost savings for business and citizens. The Commission also states that many of next year’s initiatives will also focus on making EU laws simpler and reducing costs. The Commission says that the overview report presents its measures to support Member States when implementing EU policies, as well as key enforcement statistic and actions. The Commission adds that it is actively pursuing over 1,500 ongoing infringement cases to achieve the full implementation of EU rules. Link to 2026 CommissionWork Programme and Annexes here Link Overview Report on Simplification, Implementation and Enforcement here ESAs’ Joint Committee Publishes Work Programme for 2026 On 16 October 2025, the Joint Committee of the European Supervisory Authorities (EBA, EIOPA and ESMA – the ESAs) presented its 2026 Work Programme, outlining key areas of collaboration for the coming year. The ESAs state that the upcoming Work Programme aims to strengthen the financial system’s digital operational resilience, ensure the continued protection of consumers, and identify risks that could undermine financial stability. More specifically, the ESAs will undertake joint work in 2026 to: • Ensure the effective operation of the Oversight Framework for critical third-party ICT providers under the Digital Operational Resilience Act (DORA); • Perform joint risk analyses amid ongoing geopolitical tensions and heightened uncertainties; • Further financial education and consumer protection in the EU’s financial sector, including within the context of the European Commission’s Savings and Investments Union (SIU) initiative; • Monitor developments on the securitisation market; • Collaborate on other cross-sectoral matters such as financial conglomerates, innovation facilitators and credit assessment institutions; and • Support the planned review of the Sustainable Finance Disclosure Regulation (SFDR). Link to ESAs 2026Work Programme here Commission Publishes Final Report on Study on Venture and Growth Capital Funds On 15 October 2025, the European Commission (Commission) published ‘Study of barriers to, and drivers of, the scaling-up of funds investing in innovative and growth companies’ (the Study). The Commission says that one of the key objectives of the Savings and Investments Union (SIU) is to increase and facilitate access to finance for European Union (EU) businesses. Similarly, the EU startup and scaleup strategy aims to boost investments in innovative companies. The Commission states that venture and growth capital funds could play a greater role in providing financing to EU startups, scaleups and other innovative companies. Despite some progress in the past few years, the Commission says that the EU is still falling behind the U.S., with its venture and growth capital ecosystems remaining fragmented and underdeveloped. The Study is aimed at identifying barriers to the scaling up of funds investing in innovative and growth oriented companies. The Study identified various barriers – including legal/regulatory, tax and market factors – affecting both venture capital investments across the EU and fundraising from investors, such as insurers and pension funds. The Study also presents key trends related to the venture and growth capital segments and its investors. The Commission says that by identifying the underlying issues and barriers, the Study will contribute to informing future policy work in the context of the SIU. Link to Study here