Global Trustee and Fiduciary Services Bite-Sized Issue 4 2026

20 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 • Structural developments – Market-based finance; – Sustainable finance; and – Financial innovation. Link to the Report here LUXEMBOURG The CSSF’s 2026 Priorities for Supervising the Investment Fund Sector On 31 March 2026, the Commission de Surveillance du Secteur Financier (CSSF) published a communiqué detailing its 2026 priorities for supervising the investment fund sector. The CSSF said that, on the basis of its annual risk assessment to identify the main risks associated with the activities of investment funds and investment fund managers (IFMs) and giving due consideration to the broader economic and geopolitical context, it had defined a number of key supervisory priorities and related actions to address these risks through its off-site and on-site supervisory work carried out under a risk-based approach. The CSSF said that these priorities duly consider its core mission to ensure financial stability and investor protection. The actions also draw upon the Union Strategic Supervisory Priorities (USSPs) defined by ESMA and the IOSCO’s 2026 Work Program . In view of current geopolitical risks, specific risk surveillance for monitoring these risks and their impact on the investment fund sector will continue. The CSSF said that the communiqué should not be considered exhaustive. It rather aims at drawing the attention of the market to a few prominent matters that the CSSF will address in 2026. If deemed necessary, the CSSF’s supervisory priorities and related actions may be adjusted depending on emerging risks and regulatory developments. The supervisory priorities and related supervisory actions covered by the communiqué are: • Governance/operational risks; • ICT/cyber risks; • Liquidity risks and credit risks; • Contagion risks/Interconnectedness; • Asset valuation risk; • Sustainable finance; • Costs and fees; and • ML/TF/PF risks. Link to Communiqué here Guidance on Documents and Information to be Submitted for the Assessment of the Shareholding Structure of Authorised IFMs On 2 March 2026, the CSSF published a new guidance document detailing the documents and information to be submitted by authorised IFMs for the assessment of their shareholding structure – initial authorisation andmodification of an authorised IFM (qualified and non-qualified shareholders). The document sets out the list of minimum documents and information to be provided to the CSSF to assess the shareholding structure of an authorised IFM for both the initial authorisation and any subsequent amendment to an authorised IFM (qualified and non-qualified shareholders). The CSSF reserves the right to request any additional information and documents where appropriate.