Global Trustee and Fiduciary Services Bite-Sized Issue 1 | 2026

12 QUICK LINKS AI BENCHMARKS REGULATION (UK) CRYPTOASSETS EMIR FSB FUND LIQUIDITY MIFID/MIFIR IOSCO RETAIL INVESTMENT STRATEGY SAVINGS & INVESTMENTS UNION SUSTAINABLE FINANCE/ESG ASIA PACIFIC EUROPE IRELAND NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 1 | 2026 Formal adoption of the FAQ in all EU languages is expected in the first quarter of 2026, following the publication of the Omnibus Delegated Act in the Official Journal. Link to Draft Commission Notice here Link to Commission Daily News (18/12/2025) here Simplified Sustainability Reporting and Due Diligence Rules for Businesses On 16 December 2025, the European Parliament (Parliament) approved a provisional agreement between MEPs and EU governments on updated sustainability reporting and due diligence rules for companies. The Parliament says that the revamped rules will apply to fewer companies and reduce some obligations for firms thus strengthening EU competitiveness and reduce the scope of the Corporate Sustainability Due Diligence Directive (CSDDD) and the Corporate Sustainability Reporting Directive (CSRD). The Parliament says that: • Sustainability reporting will be required from companies with over 1,000 employees and a net annual turnover of over €450 million; • Smaller companies with fewer than 1,000 employees will be protected from a shift in responsibility for reporting; • Only large corporations with more than 5,000 employees and a net annual turnover of over €1.5 billion have to carry out due diligence; and • Due diligence rules will apply from July 2029. The final text will now have to be formally approved by the Council of the EU, with the directive entering into force twenty days after its publication in the Official Journal. Link to European Press Release here Link to Text Adopted here Link to European CommissionWelcoming Political Agreement on Omnibus I Simplification Package here (9 December 2025) Sustainability Requirements Product Governance and Suitability Assessment: What Does the AFM Expect From You? On 10 December 2025, the Dutch Autoriteit Financiële Markten (AFM) conducted a survey of compliance with the sustainability requirements for product oversight & governance (POG) and the suitability assessment. The AFM says that it is positive about the steps that investment firms have taken, but compliance still needs improvement. The AFM also says that achieving a good match between investors’ sustainability preferences and investment products is crucial. To help the market make further progress, the AFM says that its ESG update contains additional clarification on the sustainability requirements for POG and the suitability assessment, as well as good practices from the market. The AFM finds that: • Investment firms have a key role in matching investors and investment products; • Surveyed firms are on track in designing the customer journey in the execution-only channel and explaining sustainability; • Additional steps are needed for assessment and collecting sustainability preferences; and • A good match requires sustained effort from investment firms – despite challenges. In relation to the last bullet above, the AFM says that it understands that investment firms face challenges in complying with the sustainability requirements. Nevertheless, the AFM expect them to continue making efforts to obtain sufficiently detailed information on clients’ sustainability preferences and on the sustainability features of investment products. The AFM calls on investment firms to take action to ensure compliance with the sustainability requirements.