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

5 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 To ensure complete consistency between the Guidelines and the RTSs as adopted by the EC, ESMA says that it has made some targeted amendments to the Guidelines. These include targeted amendments to redemption gates and transaction costs for anti-dilution LMTs. ESMA says that its report includes the revised Guidelines which integrate the above-mentioned targeted amendments. ESMA also states that it is important to publish the revised Guidelines prior to the entry into force of the RTS to ensure that stakeholders are provided with the relevant guidance in a timely manner. ESMA explains that Section 2 of the report describes the main amendments following the adoption of the RTS by the EC. Annex I contains the full text of the draft guidelines, as amended following the adoption of the RTS by the EC. Also, Annex II includes excerpts of the final Guidelines highlighting all amendments in track changes, enabling stakeholders to easily identify and review the relevant changes. ESMA says that the Guidelines in Annex I of this report will be translated into the official EU languages and published on the ESMA website. The publication of the translations will trigger a two-month period during which NCAs must notify ESMA whether they comply or intend to comply with the guidelines. The Guidelines will apply upon the application date of the RTS. Managers of funds existing before the date of application of these Guidelines should apply these Guidelines in respect of those funds after twelve months from the application date of the RTS. Link to Amended Guidelines here MAS Consults on Updates to the Guidelines on Liquidity Risk Management Practices for Fund Management Companies On 17 December 2025, the Monetary Authority of Singapore (MAS) published a Consultation Paper on Updates to the Guidelines on Liquidity Risk Management Practices for Fund Management Companies (LRMGuidelines). MAS says that the proposed updates seek to provide greater clarity on its expectations on the management of liquidity risk by fund management companies. These include: • Removal of Exchange-traded funds from the scope of the LRMGuidelines; • Alignment between redemption terms and liquidity of fund assets; • Adoption of anti-dilution liquidity management tools; • Incorporation of explicit and implicit costs, including market impact of asset sales into redemption costs; • Strengthening governance and enhancing disclosures on the design and use of liquidity management tools; and • Holistic assessment of liquidity risks. To provide further clarity on the liquidity of deposits held by Money Market Funds (MMFs), MAS also proposes to set out in the CIS Code a guidance note on the definition of “eligible deposits”, clarifying that eligible deposits made by MMFs are expected to be repayable on demand or with the right to be withdrawn by an MMF at any time.