Global Trustee and Fiduciary Services Bite-Sized Issue 7 2025

5 QUICK LINKS AIFMD CSDR ELIGIBLE ASSETS DIRECTIVE EMIR FINTECH FSB MIFID II/MIFIR SUSTAINABLE FINANCE/ESG VIRTUAL ASSETS ASIA PACIFIC EUROPE NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 7 | 2025 MIFID II/MIFIR Commission Advances Work Towards a Consolidated EU Trading Landscape for Financial Instruments On 12 June 2025, the European Commission (Commission) adopted technical standards to enable the creation of consolidated tapes, as required by theMarkets in Financial Instruments Regulation (MiFIR). The Commission says that the adopted technical standards seek to ensure that the consolidated tapes receive high quality data in a timely manner. They also specify the criteria for authorising consolidated tape providers and define the methodology for the equity tape provider to share the revenue earned from selling consolidated data with the trading venues that supplied it. The Commission states that the standards also specify the conditions for making market data available to the public in an accessible, fair and non-discriminatory manner, while ensuring fair and reasonable fees. The technical standards are adopted in the form of an implementing act and three delegated acts. The Commission says that the latter will now be transmitted to the European Parliament and the Council for their scrutiny. Additionally, the Commission plans to adopt another Delegated Act on transparency rules to support the full implementation of the consolidated tapes. Link to Implementing and Delegated Acts here SUSTAINABLE FINANCE/ESG Dutch AFM: The Role of Engagement in Sustainable Investing On 30 June 2025, the Dutch Authority for the Financial Markets (AFM) published an Occasional Paper (OP), where it had conducted an exploratory study on how asset managers carry out their engagement activities and how effective they prove to be. The AFM states in the OP that it found effectiveness is difficult to demonstrate, but that engagement can nevertheless be a valuable tool within a sustainable investment strategy. The AFM also says in the OP that there is room for further clarification and substantiation of the value case for engagement. Finally, the AFM says that the limiting of engagement efforts to a select group of companies and focusing on a limited number of specific ESG themes can increase the quality of engagement. Link to AFMOccasional Paper here ESMA Finds Improvements Needed in Supervision of Sustainability Risks and Disclosures Fund Management On 30 June 2025, the European Securities and Markets Authority (ESMA) published its report on the Common Supervisory Action (CSA) carried out in 2023 and 2024 with National Competent Authorities (NCAs) on the integration of sustainability risks and disclosures in the investment management sector. ESMA says that the level of compliance with the framework on the integration of sustainability risks and disclosures is overall satisfactory. However, ESMA says it found that improvements are needed in the integration of sustainability risks, entity level Sustainable Finance Disclosure Regulation (SFDR) disclosures and product level SFDR disclosures. ESMA states that in the course of 2023 and 2024, NCAs regularly shared their knowledge and experience to promote supervisory convergence on how they supervise the integration of sustainability risks and disclosures. The aim of the CSA was to assess, foster and enforce the compliance of supervised entities with the purpose of assessing the compliance of supervised asset managers with the relevant provisions in the SFDR, the Taxonomy Regulation and relevant implementing measures, including the relevant provision in the UCITS and AIFMD implementing acts on the integration of sustainability risks.