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

7 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 MIFID II/MIFIR ESMA Simplifies MiFID II/ MiFIR Obligations on Market Data On 23 February 2026, the European Securities and Markets Authority (ESMA) announced it had withdrawn its guidelines on the MiFID II/ MiFIR obligations on market data, effective immediately, reflecting its ongoing commitment to simplifying rules and reducing unnecessary compliance burdens for market participants. ESMA says that the decision aligns the framework with the newly applicable regulatory technical standards (RTS) on the obligation to make market data available to the public on a reasonable commercial basis (RCB). The RTS on RCB entered into force on 23 November 2025. ESMA says that market data providers authorised before that date benefit from a transition period until 22 August 2026. ESMA explains that the transition period serves solely to allowmarket data providers to align existing contractual arrangements with the new requirements in the RTS. ESMA encourages stakeholders to raise any issues related to the rules and the application of the RTS on RCB via email at RCB@esma.europa.eu. Link to ESMAWithdrawal Decision here Link toWithdrawn Guidelines here SUSTAINABLE FINANCE/ESG FCA Publishes a NewWebpage on How to Use Sustainability Labels On 27 February 2026, the Financial Conduct Authority (FCA) published a new webpage on how to use its sustainability labels as part of the SDR regime. The FCA explains that the labels are for funds with environmental or social goals and that these firms can choose to use labels if their funds meet the criteria. In particular, the FCA reminds firms of the following, among other things: • Criteria – where all products using labels must meet the general criteria, as well as criteria specific to each label (for summaries of the criteria as set out in see Annex 2 of its Policy Statement PS23/16). • How to use a label – where firms must notify the FCA of plans to use a label by completing a notification form. But that the full process to use a label will be different depending on the type of fund in scope. • Downloadable labels – where firms and distributors in scope of the SDR regime intending to use labels should download the relevant label from the form (distributors can also download from the FCA’s online page (How to use sustainability labels | FCA) ) when notifying the FCA of their intention to use a label. Link to FCAWebpage here FCA Publishes Good and Poor Practice in Relation to the SDR Regime Also on the 27 February 2026, the FCA published a new webpage, outlining its findings in relation to good and poor practice for using labels under its SDR regime. The FCA stated that the examples it set out are intended to help firms prepare pre-contractual disclosures for use of labels, following the pre-contractual disclosure examples i t published previously. The FCA set out some examples of good and poor practice in relation to each of the sustainability labels, including: Sustainability Focus Label • In relation to good practice, the FCA says: – It must be clear that the objective is to invest in assets that are environmentally or socially sustainable;