Global Trustee and Fiduciary Services Bite-Sized Issue 12 2025

8 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 The European Supervisory Authorities Designate Critical ICT Third-party Providers Under the Digital Operational Resilience Act On 18 November 2025, the European Supervisory Authorities (EBA, EIOPA, and ESMA – the ESAs) published the list of designated critical ICT third-party providers (CTPPs) under the Digital Operational Resilience Act (DORA). The ESAs said this designation marks a crucial step in the implementation of the DORA oversight framework. Through direct oversight engagement, the ESAs will assess whether CTPPs have appropriate risk management and governance frameworks in place to ensure the resilience of the services they deliver to financial entities. The aim of this engagement is to mitigate risks that could impact the operational resilience of the financial sector of the EU. Link to the CTPP List here SAVINGS AND INVESTMENT UNION Commission Proposes to Boost Supplementary Pensions to Help Ensure Adequate Retirement Income On 20 November 2025, the European Commission (Commission) announced that it had adopted a package of measures to help citizens secure adequate income in retirement by improving access to better and more effective supplementary pensions. The package forms part of the Commission’s Savings and Investments Union (SIU) Strategy which seeks to create more opportunities for households to build their wealth through capital markets, while boosting EU economic growth and competitiveness. The aim of the proposed measures is to strengthen both the demand for and the supply of supplementary pensions. The package builds upon, and supplements, the Commission’s other SIU initiatives announced to date, including on financial literacy and the Recommendation on Savings and Investment Accounts, which collectively aim to enhance EU citizens’ financial well-being, in particular by broadening options to get better returns on their savings. The proposed measures include: • Recommendations on pension tracking systems, pension dashboards, and auto-enrolment into supplementary pension schemes; • Legislative proposals to amend the Directive on Institutions for Occupational Retirement Provision (IORP) II; • Proposals to strengthen and modernise the framework to better support efficiency, scale and trust in supplementary pensions; • Legislative proposals to amend the Pan-European Personal Pension Product (PEPP) Regulation; and • Clarifying the prudent person principle. The proposals to amend the IORP II Directive and PEPP Regulation have been submitted for negotiation and agreement by the European Parliament and the Council. Link to the Proposals here Verena Ross Keynote Speech at 11th International Financial Markets Conference On 7 November 2025, Verena Ross, Chair, ESMA, delivered a keynote speech at the 11th International Financial Markets Conference, in which she underscored the urgent need to build a robust European Savings and Investment Union by addressing persistent market fragmentation. In her speech Ms Ross advocates for a balanced strategy, targeting both empowering retail investors (demand side) and enhancing market attractiveness for businesses (supply side). She highlighted the transformative but risky nature of digitalisation, including the role of “finfluencers,” and called for a streamlined investor journey alongside more centralised supervision of pan-EU market infrastructures to achieve genuinely integrated and resilient capital markets.