Global Trustee and Fiduciary Services Bite-Sized Issue 4 2026

13 QUICK LINKS CMU CONDUCT CRYPTO ASSETS EMIR FINTECH FUND LIQUIDITY IOSCO OPERATIONAL RESILIENCE SUSTAINABLE FINANCE/ESG T+1 ASIA EUROPE LUXEMBOURG NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 4 | 2026 SUSTAINABLE FINANCE/ESG AFM: “Make Sure Sustainable Fund Names are in Line With Requirements” On 19March 2026, the Netherlands Authority for the Financial Markets (AFM) published findings from an investigation that indicate that funds with sustainability-related names do not always fully comply with the European Guidelines for Sustainability-Related Fund Names (FNG). The AFM said this creates the risk that investors will not get a clear picture of the sustainable nature of a fund. The investigation consisted of an analysis of documentation at approximately 50 funds and an in- depth investigation among five managers into the assurance of ongoing compliance with the FNG. The AFM said it calls on fund Administrators to immediately check their documentation and internal monitoring against the FNG and to implement the necessary adjustments as soon as possible. These adjustments are: • Exclusions must be complete and clear – For funds that use sustainability terms in their name, certain investments are excluded based on the FNG. These exclusions must be clearly and fully included in the fund documentation. It is important that managers update their documentation and make the FNG exclusions directly accessible to investors. If information is only contained in underlying documents, it makes it more difficult to determine the sustainability approach — exactly what the FNG wants to prevent. • Ensure requirements monitoring is appropriate – The FNG prescribes which requirements funds with sustainability terms in the name must meet. This also entails the obligation to have an appropriate system in place to ensure ongoing compliance with these requirements. It is important to assess whether monitoring processes still fit the requirements: are responsibilities clear, is the data used suitable and does the process identify deviations in a timely manner? By strengthening this, managers can continuously monitor and substantiate sustainability requirements. • Act in the best interest of the investor in the event of breaches – There may be situations where investments in the portfolio are no longer in line with the FNG requirements, in which case a manager must take action. By clearly defining in advance how deviations are assessed, how this is communicated and how to act, administrators can respond faster and more consistently. This helps protect investors’ interests and reduces reputational risks — exactly what the FNG is focused on. The AFM said that a careful and complete application of the FNG strengthens investor confidence and contributes to transparent, reliable sustainable funds. By adapting and updating documentation, monitoring and policy, managers prevent repair work and show that sustainability claims are serious and verifiable. This principle also applies in full if substantive requirements are amended in the future with a view to the upcoming SFDR review. Link to AFM Statement here European Commission Seeks Feedback on Revision of Criteria for Sustainable Economic Activities On 17 March 2026, the European Commission (Commission) published two consultations seeking feedback on possible revisions to the criteria of the EU taxonomy, the classification system for sustainable economic activities. The Commission said the goal of the revision is to make the framework simpler and easier to use. The Commission said the current review builds on extensive stakeholder input gained from consultations, workshops, and a call for evidence. The draft revisions include streamlined criteria and clarifications on how to demonstrate compliance with the taxonomy. The proposals would also align the criteria with updated EU legislation and better reflect technological advances. The Commission also said the aim is to boost taxonomy adoption through easier use, improve access to green finance in the EU, and enhance market transparency through clearer disclosures. The changes cover most activities under the Climate and Environmental Delegated Acts, including forestry and environmental protection, manufacturing, energy, transport and construction, as well as for all the generic ‘do no significant harm’ appendices.