Global Trustee and Fiduciary Services Bite-Sized Issue 4 2026

8 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 FUND LIQUIDITY New European Rules for Liquidity Management On 18 March 2026, the Dutch Authority for the Financial Markets (AFM) published its third Alternative Investment Fund Managers Directive (AIFMD II) update covering various aspects of the revised AIFMD II, covering the new European rules on liquidity management. In its AIFMD II update on liquidity management tools (LMTs), the AFM discusses the new requirements around LMTs that affect both the managers of open-ended AIFs and UCITS. The new provisions are intended to make funds more resilient against market stress situations and to minimise divergent national practices on the use of LMTs and include: Fund managers of open-ended AIFs and UCITS must select at least two relevant LMTs The revised AIFMD and UCITS Directive require fund managers of open‑ended AIFs and UCITS to select at least two relevant LMTs for each fund they manage. For a money market fund (MMF), one LMT may suffice. The selection must be made from the prescribed list set out in the annexes to the revised directives. In determining the appropriate LMTs, fund managers should consider, amongst other things, the investment strategy, the nature and characteristics of the underlying assets, and the fund’s redemption policy. The LMTs must be included in the offering documentation and the fund rules or the instruments of incorporation The selected LMTs must be specified in the offering documentation as well as in the fund rules or instruments of incorporation, to enable their possible use in the interest of investors and to ensure adequate transparency. Detailed policies and procedures governing the use of LMTs are mandatory Furthermore, for the selected LMTs, fund managers must establish appropriate policies setting out the conditions for their selection, activation, deactivation and calibration, which form an integral part of the broader liquidity risk management framework. The AFM said that fund managers must notify it of the selected LMTs as well as provide the corresponding detailed policies and procedures. Finally, fund managers are required to inform the AFMwhen LMTs are activated or deactivated. As of 18 March 2026, an adjusted notification procedure is available for LMT‑related notifications. These notifications must be made through the AFM Portal. The AFM said that, for existing funds where no material changes are made to the prospectus and/or the relevant policy framework (for example, because they have already complied with the requirements under AIFMD II), it expects to collect information on the LMTs chosen at a later stage. Link to AFMAIFMD II Update here Communication to the Investment Fund Industry On 18 March 2026, the Commission de Surveillance du Secteur Financier (CSSF) published a communiqué in relation to additional liquidity management requirements for Luxembourg- domiciled UCITS and Luxembourg-authorised AIFMs that manage open-ended AIFs with effect as from 16 April 2026. In the communiqué the CSSF details the following requirements: • UCITS, or where applicable their management company, and AIFMs shall select at least two liquidity management tools (LMTs) from those referred to in Annex III, points 2 to 8 of the Law of 17 December 2010 relating to UCIs, as amended by the 2026 Law (the 2010 Law) or Annex V, points 2 to 8 of the Law of 12 July 2013 on AIFMs, as amended by the 2026 Law (the 2013 Law). This selection shall be made after assessing the suitability of those LMTs in relation to the pursued investment strategy, the liquidity profile and the redemption policy of the UCITS or AIF. • UCITS, or where applicable their management company, and authorised AIFMs that manage open‑ended AIFs shall include their selection of available LMTs in the fund or AIF rules, or in the instruments of incorporation of the UCITS or AIF. Moreover, in accordance with Annex I, Schedule A, point 1.13 of the 2010 Law and Article 21(1) of the 2013 Law, the disclosure of the selected LMTs shall be reflected in the UCITS prospectus or, for AIFs, as part of the information provided under Article 21 of the 2013 Law.