Global Trustee and Fiduciary Services Bite-Sized Issue 4 2026

17 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 1. The verification of the integration of sustainability risks in the organisational arrangements of IFMs, notably in terms of human resources and governance, investment decision or advice processes, remuneration and risk management processes and policies and management of conflicts of interest as required under SFDR. 2. The verification of the compliance of pre-contractual and periodic disclosures with the transparency requirements under the SFDR, SFDR RTS and Taxonomy Regulation. 3. The verification of the consistency of sustainability-related disclosures across the fund documentation and marketing material. 4. The verification of the compliance of IFMs’ website disclosures obligations relating to the publication andmaintenance of SFDR-related information for the investment funds they manage. 5. Conducting portfolio analysis to ensure that portfolio holdings reflect the name, the investment objective, the strategy, and the characteristics displayed in the documentation provided to investors. The CSSF said it will keep leveraging the data obtained through its dedicated SFDR IFM, pre- contractual and periodic data collection exercises to enhance its supervisory work. IFMs remain responsible for ensuring that submitted information is continuously updated. In line with the SFDR FAQ and the CSSF communiqués on SFDR, the CSSF said it will also continue to offer clarifications to the industry as needed. Supervisory priorities for issuers The CSSF said that, while the changes to Directive (EU) 2022/2464 on corporate sustainability reporting (CSRD) are still being finalised at EU level and the CSRD is still awaiting transposition in Luxembourg, it will continue to guide issuers that have chosen to voluntarily publish their sustainability statements in line with the requirements of the European Sustainability Reporting Standards (ESRS), notably through the publication of the results of fact-finding exercises, as was done in August 2025, and through bilateral exchanges to draw issuers’ attention to key points to keep in mind when developing their sustainability reports. In addition, as in previous years, ESMA, together with the European national accounting enforcers, including the CSSF, will continue to identify and implement European common enforcement priorities (the “ECEPs”) for annual reports to which particular attention will be paid when monitoring and assessing the application of the relevant reporting requirements. In the context of approving securities prospectuses, in collaboration with ESMA, the CSSF said it will continue to participate in the development of the annex defining the minimum ESG-related information to be included in the prospectus and related questions and answers and guidelines at European level. Link to Communiqué here T+1 T+1 Corporate Events Harmonised Implementation Guide On 3 March 2026, the European Central Bank published the T+1 Corporate Events Harmonised Implementation Guide (the Guide), which is designed to complement the information on corporate events included in Section 4.7 of the EU T+1 Industry Committee’s High-Level Roadmap to T+1. The Guide provides detailed guidance on the implementation of the changes to corporate events processing to facilitate harmonised implementation by market stakeholders. The information in this Guide is also intended to be included in the Single Rulebook for Corporate Events being prepared by the Advisory Group on Market Infrastructures for Securities and Collateral. The Guide covers the following: • Chapter 2 sets out the key dates applicable to corporate events in a T+1 environment; • Chapter 3 provides a high-level introduction to transaction management; • Chapter 4 sets out the rules and procedures for the processing of market claims;

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