Global Trustee and Fiduciary Services Bite-Sized Issue 5 2026

7 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 The CSSF also reminds market participants that the information of activation or deactivation of LMTs they provide through the eDesk procedure will subsequently be used to notify the required competent authorities, ESMA and, if applicable, the European Systemic Risk Board in accordance with the provisions of the 2010 Law and the 2013 Law. In addition, Luxembourg-domiciled funds subject to Part II of the 2010 Law, specialised investment funds governed by the Law of 13 February 2007 and investment companies in risk capital governed by the Law of 15 June 2004, which do not qualify as AIFs or are not managed by a Luxembourg-domiciled authorised AIFM, shall also notify the CSSF of the activation or deactivation of suspensions of subscriptions, repurchases and redemptions, as well as the creation of side pockets previously approved by the CSSF under the “LMT activation” module, as required under the respective sectoral laws. The CSSF also explains that market participants may refer to the CSSF Communiqué published on 18 March 2026 announcing the launch of the dedicated “Liquidity Management Tool (“LMT”) eDesk procedure”, for further details on the “LMT activation” module as well as additional information on the activation and deactivation of suspensions of subscriptions, repurchases and redemptions as well as the creation of side pockets. Link to CSSF Communique here MICA ESMA Publishes Statement on the End of Transitional Periods Under MiCA On 17 April 2026, the European Securities and Markets Authority (ESMA) issued a Statement to clarify supervisory expectations regarding the end of the transitional period(s) under the Markets in Crypto-Assets Regulation ((EU) 2023/1114 (MiCA)). In its previous statements on supervisory convergence (October 2023), transitional measures (December 2024), and the end of transitional periods (December 2025), ESMA has consistently emphasised the importance of timely authorisation, orderly transition, and client protection. ESMA says in its Statement that the MiCA transitional period will officially expire across the EU on 1 July 2026 . After this date, any entity providing crypto-asset services to EU clients without a MiCA licence will be in breach of EU law and must cease offering such services. ESMA also covers in its Statement: • Expectations for Crypto Asset Service Providers on Wind-down and Client Migration; • Expectations for National Competent Authorities; and • Warning for Consumers. Link to ESMA Statement here SUSTAINABLE FINANCE/ESG ESMA Consults on Guidelines on Endorsement Under the ESG Ratings Regulation On 29 April 2026, the European Securities and Markets Authority (ESMA) launched a public consultation on draft guidelines on endorsement under the ESG Ratings Regulation. ESMA says that the consultation paper sets out its proposed approach to the endorsement of non- EU ESG ratings under the regulatory framework and seeks feedback from ESG rating providers and other stakeholders on the draft guidelines. By consulting publicly, ESMA explains that it is seeking input on the proposed guidelines to ensure the guidance is clear, proportionate and workable in practice, while remaining aligned with the objectives of the ESG Ratings Regulation. ESMA welcomes comments on the consultation paper until 29 May 2026 .