Global Trustee and Fiduciary Services Bite-Sized Issue 5 2026

14 QUICK LINKS AI CRYPTOASSETS CYBER EMIR FINTECH FUND LIQUIDITY MICA SUSTAINABLE FINANCE/ESG T+1 ASIA PACIFIC EUROPE IRELAND NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 5 | 2026 ESMA Publishes Latest Edition of its Newsletter On 10 April 2026, ESMA published the latest edition of its Spotlight on Markets newsletter. ESMA says that this edition opens with ESMA’s actions to simplify the retail investor journey and make investing more accessible, setting out steps to support retail participation in capital markets. ESMA says that top news highlights include the publication of the first Trends, Risks and Vulnerabilities (TRV) report of 2026, which points to a high-risk environment for EU financial markets, as well as analysis showing that new investment funds are helping to reduce costs for investors. ESMA also states that key publications featured in this edition include: • Annual transparency calculations for equity and equity-like instruments; • A joint EBA-ESMA consultation on revised suitability assessment requirements for banks and investment firms; • ESMA’s proposals to simplify MiFID II/MiFIR obligations on market data; and • A Statement supporting the smooth implementation of the Listing Act and simplified prospectus compliance for issuers. Link to ESMA Newsletter here IRELAND Staff Insights: Availability and Use of Liquidity Management Tools in Irish-domiciled Investment Funds On 9 April 2026, the Central Bank of Ireland (Central Bank) published ‘Staff Insights: Availability and Use of Liquidity Management Tools in Irish-domiciled Investment Funds’. In the Staff Insights, the following key insights were identified: • The use of price-based liquidity management tools (P-LMTs) can mitigate first-mover advantage dynamics in funds with liquidity mismatches, as well as better allocate transaction costs across fund investors. A novel survey carried out by the Central Bank has found that these tools are widely available in Irish-domiciled investment funds, with 84% of funds having at least one such tool. Anti-dilution levies (ADLs) are the most commonly available P-LMT, followed by redemption fees and swing pricing. • The survey also highlights that while P-LMT availability is relatively high, the use of these tools lag availability, with around one-third of funds using P-LMTs at least once over the 2022- 2023 survey period. There is a lack of consistency in the application of P-LMTs, with the main determining factor behind the choice and use of specific tools appearing to be a desire for standardisation across all managed funds within a management company, as opposed to asset class-specific factors. • Few of the funds surveyed explicitly incorporate the expected price movement as a result of the fund’s trading activity (an implicit cost known as market impact) in addition to the bid/ask spread, as recommended in the Financial Stability Board/International Organization of Securities Commissions recommendations and guidance. The inclusion of a specific market impact estimate was higher among funds trading in less liquid markets, where the bid/ask spread may not fully capture all implicit transaction costs. Link to Staff Insights here