Global Trustee and Fiduciary Services Bite-Sized Issue 4 2026

16 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 The CSSF’s Supervisory Priorities in the Area of Sustainable Finance On 2 March 2026, the Commission de Surveillance du Secteur Financier (CSSF) published a Communiqué providing a general overview of the CSSF’s supervisory priorities in the area of sustainable finance. The CSSF said that integrating sustainability considerations and effectively managing sustainability risks should not be seen only as stemming from regulatory requirements, but also as essential drivers of long-term financial strategies and resilience. While the regulatory framework in relation to sustainable finance is evolving, the CSSF said its supervisory priorities in the area of sustainable finance are designed to support a transparent, credible, and coherent transition of the financial sector towards long-term sustainability objectives. The CSSF said that the document should not be interpreted as an exhaustive account. It rather aims at drawing the attention of the financial sector to a number of prominent matters to be addressed in this area. The CSSF also stated that, if deemed necessary, its supervisory priorities may be adjusted depending on emerging risks and regulatory developments. Focus areas Supervisory priorities for credit institutions and investment firms The CSSF said that, when shaping and calibrating its supervisory priorities, it will take due consideration of the ongoing EU regulatory developments concerning sustainability-related transparency and disclosure obligations, including the review of Regulation (EU) 2019/2088 and Implementing Regulation 2024/3172 (‘Pillar 3 disclosure ITS’). 1. Transparency and disclosures: The CSSF said it will continue to ensure the supervision of disclosure obligations for credit institutions and investment firms which fall in the scope of Regulation (EU) 2019/2088 on sustainability related disclosures in the financial services sector (SFDR) through the long form report, as revised pursuant to Circular CSSF 22/821 (as amended by Circulars CSSF 24/865, CSSF 23/845 and CSSF 25/897) and Circular CSSF 24/853 (as amended by Circulars CSSF 25/870 and 26/904), respectively. Answers to the self-assessment section of the long form report will be assessed as part of the prudential supervision and will enable the CSSF to take enforcement measures where appropriate. Additionally, the CSSF will continue to carry out on-site inspections on depositary entities, integrating ESG- related investment restrictions monitoring, as laid down in the ESMA Supervisory Briefing on Sustainability risks and disclosures in the area of investment management. 2. Risk management and governance: For credit institutions, prudent management of climate and nature-related risks remains one of the priorities for the banking sector, as per the SSM’s supervisory priorities for 2026-2028. The CSSF said it will continue to review and monitor risk integration in order to ensure proper alignment of the banking sector with the its expectations set out in Circular CSSF 21/773 and with the EBA Guidelines on the management of ESG risks, implemented in Luxembourg through Circular CSSF 26/905. In addition, the CSSF said it will continue its on-site inspections on governance and credit risks, integrating ESG aspects, and may also conduct on-site inspections specifically focused on ESG risks. 3. MiFID rules related to sustainability: The CSSF said it will continue to ensure the supervision of MiFID rules related to sustainability. In this context, the CSSF said it will adopt a proportional approach in its supervisory practices, ensuring that both the scope and intensity of supervisory actions take into consideration not only the specific risks and circumstances of supervised entities but also the remaining uncertainties and potential evolution of the regulatory landscape. Supervisory priorities for the asset management industry The CSSF said it will continue to monitor Investment Fund Managers’ (IFMs) compliance with the sustainability-related provisions as set forth under the SFDR, the SFDR RTS and Regulation (EU) 2020/852 (the Taxonomy Regulation). In doing so, the CSSF said it will take due consideration of the principles and guidance laid down in the ESMA Supervisory Briefing on Sustainability risks and disclosures in the area of investment management as well as the ESMA Guidelines on funds’ names using ESG or sustainability-related terms. The CSSF said it will focus on the following priority areas applying a risk-based approach, integrating on-site and off-site supervision: