Global Trustee and Fiduciary Services Bite-Sized Issue 9 2025

8 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 FCA goes on to list six specific observations covering: • Risk management; • Audience; • Accessibility; • Data; • Proportionality; and • Regulatory clarity. The FCA says that, in light of its findings, it has updated its sustainability reporting requirements webpage to clarify how firms in scope of both the TCFD and Sustainability Disclosure Requirements (SDR) rules can report efficiently under both regimes. The FCA says it is also considering how to streamline and enhance its sustainability reporting framework through: • Simplifying disclosure requirements and easing unnecessary burdens on firms; • Maintaining good outcomes for clients and consumers and improving the decision-usefulness of reporting, by building on the work of SDR to improve trust and reduce greenwashing; and • Promoting international alignment. Link to the Findings here ESAs Publish Updated Q&As on Sustainable Finance Disclosure Regulation On 4 August 2025. the European Supervisory Authorities (EBA, EIOPA and ESMA – the ESAs) published an updated version of their questions and answers (Q&As) on the Sustainable Finance Disclosure Regulation (SFDR) and on Commission Delegated Regulation (EU) 2022/1288 (SFDR Delegated Regulation). Q&As on the following issues have been added: • The meaning of the term ‘water usage’; • Clarification of the phrase ‘per squaremeter’ in calculating energy consumption for real estate assets; • Best practice about disclosing percentages of environmentally sustainable investments and socially sustainable investments; and • Whether financial products should calculate top investments of shares of investments in periodic disclosures in a specific way over the reference period. Link to the Updated Q&As here T+1 FCA: Are Firms Ready for T+1 in the UK and Europe? On 14 August 2025, the Financial Conduct Authority (FCA) provided an update on its expectations and plans as firms move to T+1 on 11 October 2027. The FCA says that on 16 July 2025, its InterimHead of Capital Markets took part in a fireside chat at the Accelerated Settlement Taskforce (AST) industry event, ‘The Journey to T+1 in the UK and Europe – will you be ready?’ The FCA explains that the event marked almost six months since the AST published its T+1 UK Implementation plan and focused on market participants’ preparations for the UK move to T+1 on 11 October 2027. A poll taken at the event indicated that approximately 87% of respondents had already identified the changes they need to make to prepare for T+1.