Global Trustee and Fiduciary Services Bite-Sized Issue 2 2026

11 QUICK LINKS AIFMD BENCHMARKS REGULATION CRYPTOASSETS FINTECH FUND LIQUIDITY MIFID II/MIFIR MONEY MARKET FUNDS OPERATIONAL RESILIENCE SUSTAINABLE FINANCE/ESG T+1 ASIA PACIFIC EUROPE NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 2 | 2026 Sustainable Finance Regulatory Timeline On 13 January 2026, ESMA published an updated version of implementation timeframes for various sustainability-related provisions under EU law, covering the Sustainable Finance Disclosures Regulation (SFDR), Taxonomy Regulation, the Corporate Sustainability Reporting Directive (CSRD), the Benchmarks Regulation (BMR), European Green Bonds Regulation (EuGBR) and the Environmental, Social and Governance Rating Regulation (ESGRR). The document details key events between 2023 and 2029. Link to Timeline here ESAs Publish Joint Guidelines on ESG Stress Testing On 8 January 2026, the European Supervisory Authorities (EBA, EIOPA and ESMA - the ESAs) published their Joint Guidelines on ESG stress testing. The ESAs state that these Guidelines provide national insurance and banking supervisors with clear guidance on how to integrate ESG risks into supervisory stress tests, both when using established frameworks and when conducting complementary assessments of ESG risk impacts. The ESAs say that the Guidelines set common standards for embedding ESG risks into stress testing methodologies across the EU’s financial system. They provide guidance on designing ESG- inclusive stress tests and outline the necessary organisational and governance arrangements. The ESAs say that the Guidelines are designed to support a consistent, long-term approach to ESG stress testing while allowing flexibility to accommodate future methodological advances and improvements in data availability. Importantly, the ESAs point out, they do not introduce new requirements for competent authorities to carry out ESG-focused supervisory stress tests. Next steps The Guidelines will be translated into all the official languages of the EU in the first quarter of 2026. They will be subject to a ‘comply or explain’ procedure by the National Competent Authorities within two months of the publication of the translated Guidelines. The joint Guidelines will apply from 1 January 2027. Link to the Joint Guidelines here Update on UK Government Process to Finalise UK Sustainability Reporting Standards On 5 January 2026, the Department for Business and Trade (DBT) wrote to the Financial Conduct Authority (FCA), providing an update on the development of the UK Sustainability Reporting Standards (UK SRS). Key takeaways from the DBT’s letter include: • UK SRS Development: The DBT is finalising the UK SRS, which will align with the FCA’s plans to consult on their adoption for listed companies in January 2026; • Implementation Challenges & Reliefs: Stakeholder feedback emphasised the need for sufficient time to implement the standards and sought clarity on how reliefs within UK SRS would interact with FCA rules, including regarding transitional periods; and • Timing of Application: Specific time-references for reliefs will be removed from the standards and their application timing will be set out in government regulations or FCA rules or by any other relevant authority. The final UK SRS S2 will also incorporate amendments from the International Sustainability Standards Board (ISSB) related to IFRS S2. Link to the Letter here