Global Trustee and Fiduciary Services Bite-Sized Issue 12 2025

11 QUICK LINKS COSTS & CHARGES CRYPTOASSETS FINTECH FSB IOSCO OPERATIONAL RESILIENCE SAVINGS AND INVESTMENT UNION SUSTAINABLE FINANCE/ESG T+1 ASIA PACIFIC EUROPE NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 12 | 2025 Link to Questions and Answers here Link to the Set of Amendments to the SFDR here Link to Commission Newsletter here NGFS Publishes Updated Guide on Climate Scenario Analysis On 13 November 2025, the Network for Greening the Financial System (NGFS) released an updated edition of its Guide on Climate Scenario Analysis, building on the foundation laid by the first edition published in 2020. The NGFS says this new edition reflects the significant progress made in the field of climate scenario analysis over the past five years and incorporates best practices in climate scenario design, data, and modelling. The NGFS says a key addition in this edition is the emphasis on short-term scenarios, which are gaining importance for evaluating near-term financial risks arising from climate change and evolving climate policy measures. By consolidating advancements and innovations, the NGFS says the Guide serves as a practical reference for authorities and financial institutions aiming to integrate climate scenario analysis into their risk management frameworks and decision-making processes. The NGFS says it intends for the Guide to be a living document, evolving in step with ongoing developments in the field of climate-related data, modelling approaches, and supervisory practices. Link to the Guide here EU Taxonomy - Review of Climate and Environmental Delegated Acts On 7 November 2025, the European Commission issued a call for evidence (CfE) on the review of the EU taxonomy climate delegated act and environmental delegated act. The Commission says the initiative reflects its recent broader political priorities, particularly the commitment to reduce reporting burdens for companies and support sustainable finance through clearer and more proportionate rules. The Commission says it also responds to the legal obligation under the Taxonomy Regulation to regularly review and, where appropriate, amend the technical screening criteria. The Commission says the initiative, in the form of a package of two Delegated Regulations, aims to improve the clarity, usability, legal certainty, and cost-effectiveness of the EU Taxonomy. The Commission further says it seeks to address identified implementation challenges by clarifying technical screening criteria, including the ‘do no significant harm’ criteria, aligning themwith recent updates of related EU legislation, and eliminating unnecessary complexity. The Commission says this will support more consistent and efficient application across sectors andMember States, while easing the reporting burden and lowering compliance costs for companies. The Commission says it is considering targeted amendments to improve the usability of, simplify and clarify the criteria while maintaining their robustness and credibility. According to the Commission, these may include adjustments to specific technical screening criteria, improved definitions, clearer requirements for proving compliance with criteria, removal of duplicative or disproportionate requirements, and clearer references to related EU rules. The Commission says the approach will remain proportionate, with changes focused on areas where there is clear evidence of practical barriers or misalignment. The CfE closed on 5 December 2025. The Commission has targeted Q2 2026 to adopt the resulting delegated regulations. Link to the CfE here TNFD: Recommendations for Upgrading the Nature Data Value Chain for Market Participants On 6 November 2025, the Taskforce on Nature-related Financial Disclosures (TNFD) published a series of recommendations proposed by the TNFD to seek to catalyse a whole-of-value-chain mindset shift about the discoverability, quality and accessibility of nature-related data as a strategic global public good. Together, the TNFD says, they also seek to unlock a much-needed new source of finance for the collection of essential state-of-nature data through the operation of a global common data facility.