Global Trustee and Fiduciary Services Bite-Sized Issue 3 | 2026

13 QUICK LINKS AI DIGITAL ASSETS EMIR FINTECH FSB IOSCO MIFID II/MIFIR SUSTAINABLE FINANCE/ESG ASIA PACIFIC EUROPE LUXEMBOURG NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 3 | 2026 • Firms should take appropriate steps to identify, prevent, or manage conflicts of interest that may arise from the offering of these products. Link to Statement here ESMA Publishes its 2027-2029 Programming Document On 5 February 2026, ESMA published its Programming Document for 2027-2029 (Programming Document). In its Foreword, ESMA says that the Programming Document comes at a moment of significant change for the European financial system. ESMA’s work in the coming years will be shaped by a rapidly evolving regulatory and market landscape, as well as by broader economic and geopolitical developments. ESMA adds that the overall environment remains characterised by uncertainty, modest economic growth, and heightened global tensions, all of which influence market behaviour, investment conditions, and risks to financial stability. Looking ahead, ESMA says that its priorities for the years to come include: • Supporting the implementation of the EU political priorities in relation to the Simplification and Burden Reduction agenda and preparation for the Savings and Investment Union; • Deepening supervisory convergence and effective supervision; • Enhancing market data and digital capabilities; and • Contributing to reforms that make EU capital markets more integrated, accessible, and efficient. ESMA will also advance supervisory reporting reforms to reduce compliance costs while improving data quality, including through the new UCITS reporting regime and the rollout of integrated reporting frameworks. Furthermore, ESMA will continue the phased implementation of the European Single Access Point, the EU-wide digital platform for public financial and sustainability information, with the first phase scheduled to launch in second half of 2027. As a risk-based and data-driven authority, ESMA says that it will continue to enhance its efficiency amongst others by expanding its Data Platform to foster cooperation among authorities, pool efforts, and build synergies through shared data, as well as by deploying of supervisory tools powered by artificial intelligence. Link to ESMA’s 2027-2029 Programming Document here LUXEMBOURG CSSF Updates its FAQConcerning the Luxembourg Lawof 17 December 2010with Regard to the Portfolio Transparency Requirements for UCITS ETFs and the Holding of Ancillary Liquid Assets On 17 February 2026, the Commission de Surveillance du Secteur Financier (CSSF) published an update of its FAQ concerning the Luxembourg Law of 17 December 2010 relating to undertakings for collective investment. The CSSF says that with a view to promote supervisory convergence at European level, this update modifies question 12.1 providing specific guidance on the portfolio transparency requirements for UCITS ETFs. Firstly, it clarifies that the guidance applies to all UCITS ETFs and not only to actively managed UCITS ETFs. Secondly, it clarifies that, besides the information that market makers and authorised participants receive typically on a daily basis on portfolio holdings to ensure an efficient arbitrage mechanism and an active secondary market for ETFs, Investment Fund Managers have to publish, going forward, the detailed portfolio holdings to all investors at least on a quarterly basis (instead of the monthly frequency applicable so far) with a maximum time lag of 30 business days.