Global Trustee and Fiduciary Services Bite-Sized Issue 3 2025

8 QUICK LINKS CRYPTOASSETS CSDR EMIR FINTECH FSB OPERATIONAL RESILIENCE SUSTAINABLE FINANCE/ESG T+1 ASIA PACIFIC EUROPE IRELAND LUXEMBOURG NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 3 | 2025 The EC states that the main changes in the area of sustainability reporting (CSRD and EU Taxonomy) will: • Remove around 80% of companies from the scope of CSRD, focusing the sustainability reporting obligations on the largest companies which are more likely to have the biggest impacts on people and the environment; • Ensure that sustainability reporting requirements on large companies do not burden smaller companies in their value chains; • Postpone by two years (until 2028) the reporting requirements for companies currently in the scope of CSRD and which are required to report as of 2026 or 2027; • Reduce the burden of the EU Taxonomy reporting obligations and limit it to the largest companies (corresponding to the scope of the CSDDD); • Introduce the option of reporting on activities that are partially aligned with the EU Taxonomy; • Introduce a financial materiality threshold for the Taxonomy reporting and reduce the reporting templates by around 70%; and • Introduce simplifications to the most complex “Do no Significant harm” (DNSH) criteria for pollution prevention and control related to the use and presence of chemicals that apply horizontally to all economic sectors under the EU Taxonomy. The EC has also announced changes to simplify sustainability due diligence and is also proposing a series of amendments to simplify and optimise the use of several investment programs including InvestEU, EFSI, and legacy financial instruments. Next steps The EC says that the legislative proposals will now be submitted to the European Parliament and the Council for their consideration and adoption. The changes on the CSRD, CSDDD, and CBAM will enter into force once the co-legislators have reached an agreement on the proposals and after publication in the EU Official Journal. The EC invites the co-legislators to treat this omnibus package with priority, in particular the proposal postponing certain disclosure requirements under the CSRD and the transposition deadline under CSDDD, as they aim to address key concerns identified by stakeholders. The draft Delegated Act amending the current delegated acts under the Taxonomy Regulation will be adopted after public feedback and will apply at the end of the scrutiny period by the European Parliament and the Council. Link to European Commission’s Q&A here Link to Omnibus I Proposals here Link to Omnibus II Proposals here Link to Call for Evidence on Taxonomy Delegated Acts here FCA Delays Policy Statement on Extending SDR to Portfolio Management On 14 February 2025, the Financial Conduct Authority (FCA) announced that it wants to ensure an extension of its Sustainability Disclosure Requirements (SDR) to portfolio management delivers good outcomes for consumers, is practical for firms and supports growth of the sector. In order to do this the FCA says it will take the necessary time to deliver these outcomes, so no longer intends to publish a Policy Statement in Q2 2025. The FCA states that it will continue to reflect on the feedback and provide further information in due course. Link to FCA Announcement here