Global Trustee and Fiduciary Services Bite-Sized Issue 9 2025

7 QUICK LINKS CRYPTOASSETS CYBERSECURITY EMIR (UK) FINTECH MIFID/MIFIR (UK) SUSTAINABLE FINANCE/ESG T+1 ASIA PACIFIC AUSTRALIA EUROPE LUXEMBOURG NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 9 | 2025 The consultation period closes on 19 September 2025. The TFC says a second consultation on revised guidelines will follow later in 2025, with the final guidelines expected to be published in 2026. Link to the Consultation here Australian Treasury Publishes Consultation on Climate-related Transition Planning Guidance On 15 August 2025, the Australian Government published a consultation on its developing guidance on best practices for climate-related transition planning. The guidelines are one of the priorities under the Australian Government’s Sustainable Finance Roadmap published in June 2024. There are two parts to the consultation paper: • Part A - outlines the role of transition planning and proposed design approach. • Part B - provides illustrative draft guidance aligned with the proposed approach. The guidance aims to • Support international alignment to make it easier to compare transition plans; • Outline domestic policy and regulatory considerations; • Balance encouraging high ambition with providing flexibility; and • Take a climate first but not only approach. The consultation period closes on 24 September 2025. The Australian Government says it is committed to publishing the guidance by the end of 2025. Link to the Climate-related Transition Planning Guidance - Consult hub here Sustainability-linked Loans Market: 2 Years On On 14 August 2025, the Financial Conduct Authority (FCA) published a follow-up letter to share insights from its ongoing engagement with banks active in the sustainability-linked loans (SLL) market, as part of its aim to be a smarter regulator and to deepen trust in the market. The FCA says that since its previous letter in 2023, which highlighted some concerns, it has seen the market for SLLs mature, with better practice and more robust product structures. The FCA goes on to say that there are still barriers to scaling the SLL market and some concerns around incentives, but the improvements it has observed are important steps in the development of a credible transition finance ecosystem. The FCA says that it will continue to monitor the SLL market as part of its wider work on transition finance and welcomes further constructive dialogue with banks. Link to Follow-up Letter here Climate Reporting by Asset Managers, Life Insurers and FCA-regulated Pension Providers On 6 August 2025, the FCA published its findings and next steps following its review into firms’ climate reporting in line with its climate disclosure rules for asset managers, life insurers and FCA- regulated pension providers. These require firms to disclose climate-related information in line with the Taskforce on Climate-related Financial Disclosures (TCFD) recommendations. The FCA says that it found that its rules have increased firms’ consideration of climate risks and supported their integration into firms’ decision-making. Firms were more transparent with their clients and consumers but encountered some challenges with the availability of data and consistent, well-developed methodologies. They also considered some information too complex for retail investors to engage with and thought the regime could be less granular and more proportionate. They saw opportunities to simplify reporting, particularly given their broader sustainability disclosure obligations.