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

13 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 In its second ESG update, the AFM explains that it provides additional guidance and examples to help investment firms make further progress. Link to AFM Press Release here Link to Second ESG Update (Dutch Only) here FCA Sets Out Proposals to Make ESG Ratings Transparent, Reliable and Comparable On 1 December 2025, the UK Financial Conduct Authority (FCA) published CP25/34: ESG (Environmental, Social, Governance) ratings: proposed approach to regulation. In CP25/34, the FCA says that it is consulting on proposed rules and guidance for the regulation of ESG ratings providers, following recent legislation fromHM Treasury to bring ESG ratings within its regulatory perimeter. The FCA says that it wants to: • Make ESG ratings more transparent, reliable and comparable; • Support better decision-making and greater confidence in the market; and • Be proportionate and support growth in sustainable finance. The FCA also states that the move is estimated to deliver around £500m in net benefits over the next decade. The FCA adds that its research shows around half of those who use ESG ratings are worried about how they are built (55%) and how transparent they are (48%). The FCA’s proposals aim to address this and focus on four areas: 1. Increased transparency – allowing easier comparisons for the benefit of both those who use ratings and those who are rated. 2. Improved governance, systems and controls – to ensure clear decision-making and strong oversight and quality assurance. 3. Identification and management of conflicts of interest. 4. Setting clear expectations for stakeholder engagement and complaints handling. The FCA explains that there are also proposals on applying existing FCA rules to firms coming into the FCA’s remit. The proposed rules are designed to be proportionate to business size and risk. The FCA also highlights that the proposals draw on the existing voluntary industry code of conduct and International Organization of Securities Commissions recommendations to support consistency and international competitiveness. CP25/34 is open until 31 March 2026 and the FCA says that it expects final rules to be published in Q4 2026, with the new regime coming into effect from June 2028. Link to Consultation here Link to Research Note here Link to the Financial Services and Markets Act 2000 (Regulated Activities) (ESG Ratings) Order 2025 here (18 December) Link to Explanatory Memorandum here (18 December) ASIA PACIFIC FSTB and SFC Conclude Consultations on Virtual Asset Dealer and Custodian Regimes, Further Consult on Two New Regimes On 24 December 2025, the Financial Services and the Treasury Bureau (FSTB) and the Securities and Futures Commission (SFC) published consultation conclusions on legislative proposals to regulate virtual asset (VA) dealing and custodian service providers in Hong Kong. At the same time, the FSTB and the SFC commenced a further consultation on new regimes for providers of VA advisory and management services.