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

4 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 the meantime, ESMA states that it will develop additional instructions on how to report according to the templates included in the RTS. These instructions will provide clarity and consistency for reporting entities and ensure that competent authorities receive meaningful and consistent information. Reporting of information on clearing activity at recognised Third Country CCPs (Article 7d of EMIR) ESMA says that counterparties subject to the new reporting obligation in relation to their clearing activity at recognised Third-Country CCPs (Article 7d of EMIR) are expected to report to their competent authorities annually. The content and details of this reporting will be specified by ESMA in the relevant RTS and Implementing Technical Standards (ITS). However, ESMA says that until these standards are published, there could be inconsistencies in the way reporting will be performed, and supervised entities may encounter difficulties in reporting meaningful information to their competent authorities and may be subject to unnecessary operational burden. Therefore, it is expected that the first reporting under Article 7d of EMIR on 2025 data will be submitted together with the 2026 reporting cycle, following the implementation of the necessary Level 2 measures. ESMA says that both approaches are meant to ensure harmonised reporting while guaranteeing proportionality and reducing unnecessary burden for supervised entities. Link to ESMA Statement here FSB FSB Reports Continued Growth in Nonbank Financial Intermediation in 2024 On 16 December 2025, the Financial Stability Board (FSB) published its annual Global Monitoring Report on Nonbank Financial Intermediation (NBFI). The FSB says that the report describes broad trends in nonbank financial intermediation in 2024 across 29 jurisdictions that account for over 90% of global GDP. The report also provides the main findings from 2025’s monitoring exercise. Finally, the Global Monitoring Report also highlights severe limitations in the availability of data for private credit in statistical and regulatory reports. The FSB says that the assessment of private assets’ potential impact on financial stability will be an important part of the overall FSB’s surveillance work in the year ahead. Link to Global Monitoring Report here FUND LIQUIDITY ESMA Publishes Report on Amended Guidelines on LMTs of UCITS and Open-ended AIFs On 18 December 2025, the European Securities and Markets Authority (ESMA) released its Report on Amended Guidelines on Liquidity Management Tools (LMTs) of Units for Collective Investment in Transferrable Securities (UCITS) and Alternative Investment Funds (AIFs). On 15 April 2025, ESMA published the Final Report on the Regulatory Technical Standards (RTS) on LMTs under the AIFMD and UCITS Directive and the Final Report on the Guidelines on LMTs of UCITS and open-ended AIFs. Following their publication, the draft RTSs were submitted to the European Commission (EC) for adoption. The EC formally adopted the draft RTS on 17 November 2025, making a number of amendments to the original text. ESMA says that some of these amendments have an impact on the Guidelines.