Global Trustee and Fiduciary Services Bite-Sized Issue 5 2026

8 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 Following the consultation, ESMA says that it will assess the responses and decide on the final form of the guidelines, in line with its mandate under the ESG Ratings Regulation. Finally, ESMA states that further information on the outcome of the consultation and the adoption of the guidelines will be communicated before the end of July 2026 . Link to Consultation here ESMA Support ESEF Implementation with Updated Taxonomy On 21 April 2026, ESMA published the 2025 European Single Electronic Format (ESEF ) XBRL taxonomy files, together with an updated ESEF Conformance Suite. ESMA states that these materials support issuers and software vendors in preparing 2026 IFRS consolidated financial statements using the most up‑to‑date ESEF format. ESMA explains that the 2025 taxonomy reflects the introduction of IFRS 18 Presentation and Disclosure in Financial Statements, effective from 1 January 2027 , with early application permitted. The ESEF taxonomy includes two entry points, allowing issuers to report under either IAS 1 and IFRS 18. ESMA says that this approach facilitates prompt understanding of the new structure, encourages timely preparation, and lowers implementation risks. ESMA also says that it does not plan to amend the ESEF RTS or taxonomy in 2026. This follows the IFRS Foundation’s decision not to issue a 2026 IFRS Accounting Taxonomy update and will provide greater regulatory stability and more time for implementation. In terms of next steps, ESMA says that it encourages issuers and software providers to consult the IFRS Foundation’s guidance on the use of the 2025 IFRS Accounting Taxonomy for 2026 reporting periods when preparing for upcoming reporting requirements. Link to ESMA Announcement here EU Commission Adopts RTS on ESG Rating Activities and Disclosures for ESG Rating Products On 21 April 2026, the EU Commission adopted two Delegated Regulations (DRs) laying down regulatory technical standards (RTS) under Regulation (EU) 2024/3005 (the ESG Rating Regulation). The first DR specifies measures and safeguards that ESG rating providers should put in place to separate their ESG rating activities from other activities and require that ESG rating providers: • Put in place separate organisational structures and working environments for employees and other persons involved in the rating process from any of the activities listed in Article 16(1) of the ESG Rating Regulation, and subject them to regular self-declarations attesting employees’ non- involvement in such Article 16(1) ESG rating activities; • Intending to provide investment services and/or insurance and reinsurance activities implement additional technical and internal control measures; and • When, or intending to, provide benchmarks, adopt additional specific safeguards ensuring that: – Employee compensation remains unaffected by any conflicts of interest related to benchmark activities; – ESG ratings are produced and offered independently of the provision of benchmarks; and – Any actual or potential conflicts of interest are assessed and documented before entering a contract for the provision of ESG rating activities. The second DR specifies the elements of ESG rating products that must be disclosed to the public and to users of ESG ratings, rated items, and issuers of rated items. This DR provides details on: • The content of disclosures on rating products, rating methodologies (including limitations in data sources, information and assumptions), the organisational disclosures related to rating providers, and the revision of data and methodologies; plus the form that these disclosures should take.