Global Trustee and Fiduciary Services Bite-Sized Issue 5 2025

12 QUICK LINKS AIFMD (UK) CRYPTOASSETS DATA EMIR FINTECH FSB IOSCO MARKET ABUSE REGULATION MICA MIFID II/MIFIR SUSTAINABLE FINANCE/ ESG ASIA PACIFIC AUSTRALIA EUROPE LUXEMBOURG NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 5 | 2025 Sustainability and Due Diligence: MEPs Agree to Delay Application of New Rules and entry into the Official Journal of the European Union On 2 April 2025, the European Parliament voted to postpone the application dates for new EU laws on due diligence and sustainability reporting requirements. The amendments to delay these regimes entered the Official Journal of the European Union (OJEU) on 16 April. The new due diligence rules (CSDDD) require companies to mitigate their negative impact on people and the planet. Member states will now have an extra year to transpose the rules into national legislation. The one-year extension will also apply to the first wave of businesses to be affected, namely: EU companies with over 5,000 employees and net turnover higher than EUR 1.5 billion, and non-EU companies with a turnover above this threshold in the EU. These companies will now have to apply the rules from 26 July 2028. The date of application will be and remains the same for the second wave of companies (those in the EU with over 3,000 employees and net turnover higher than EUR 900 million, and non-EU companies with turnover above that threshold in the EU); third wave companies remain in scope from July 2029. Application of the sustainability reporting directive (CSRD) will also be delayed by two years for the second and third waves of companies covered by the legislation. Link to the Amendments as published in the OJEU here FCA Issues Feedback on DP23/1: Finance for Positive Sustainable Change On 2 April 2025, the FCA published details of the feedback it had received from its discussion paper (DP23/1) on sustainability-related governance, incentives and competence in regulated firms, published in February 2023. The FCA said it welcomed the level of engagement from respondents and the importance with which respondents generally regarded the themes and issues in DP23/1. The insights it gained from the responses and in its dialogue with stakeholders have been very important in building its understanding of the state of play, including challenges and opportunities. Since the FCA published DP23/1, it has introduced rules relating to some of the themes. For example: • The Consumer Duty came into force on 31 July 2023. • SDR and labelling rules were published on 28 November 2023. • The Anti-Greenwashing Rule came into effect on 31 May 2024. The FCA says it is encouraging that many respondents to DP23/1 acknowledged the importance of these measures. The FCA states that it is not currently considering introducing new rules on the themes discussed in DP23/1, but the DP’s themes remain important to firms’ success in: • Embedding sustainability considerations. • Delivering value to consumers. • Supporting market integrity. The FCA says it will continue to promote the themes discussed in DP23/1 through other initiatives, both domestically and internationally and it will continue to: • Carry out supervisory engagement. • Bring market participants together to develop market-led solutions. • Influence on the global stage. Link to the Feedback here