Global Trustee and Fiduciary Services Bite-Sized Issue 6 2026

12 AIFMD CRYPTOASSETS FINTECH FSB IOSCO MIFID II/MIFIR MONEY MARKET FUNDS OPERATIONAL RESILIENCE SUSTAINABLE FINANCE/ESG T+1 ASIA PACIFIC EUROPE LUXEMBOURG NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 6 | 2026 Quick LInks Also explained in its press release, on 4 April 2024, the SEC says that it stayed the climate disclosure rules pending completion of consolidated litigation in the U.S. Court of Appeals for the Eighth Circuit. And on 27 March 2025, the SEC voted to end its defence of the final rules. Finally, on 12 September 2025, the SEC says that the Eighth Circuit issued an order holding the consolidated petitions for review in abeyance until such time as the SEC reconsiders the challenged rules by notice-and-comment rulemaking or renews its defence of the climate disclosure rules. In its latest proposal, the SEC says it is now proposing to rescind the climate disclosure rules in their entirety because they exceed the scope of the agency’s statutory authority. The SEC adds that, even if it had authority to adopt such final rules, the SEC believes there are independent, compelling policy reasons to rescind them entirely. The SEC states that they: • Are unnecessary and inconsistent with a registrant-specific, materiality-based approach to disclosure that best serves the interests of registrants and investors. • Stray well beyond the policy concerns of the federal securities laws. • Impose substantial costs on public companies and their shareholders that are not justified by the informational benefits they may provide to some investors. • And are at odds with the SEC’s policy objectives of facilitating capital formation and promoting public company status. The public comment period will remain open for 60 days following the publication of the proposing release in the Federal Register. Link to Proposed Rule here Link to SEC Fact Sheet here Financing Climate Solutions: Exploring findings from the Transition Finance Pilot On 21 May 2026, the Financial Conduct Authority (FCA) published a report setting out its findings from the Transition Finance Pilot examining barriers to scaling finance for climate solutions. The Transition Finance Pilot was a market engagement exercise led by the FCA and supported by the Prudential Regulation Authority (PRA) and the Green Finance Institute (GFI). It was announced as part of the Financial Services Growth and Competitiveness Strategy in July 2025. The FCA says the findings set out in the report were informed by a review of published literature and a wide programme of engagement. Over several months, the FCA says it engaged with more than 45 market participants across two main categories: • Capital providers across the project lifecycle, including venture capital, private equity, banks, institutional investors, and public finance institutions. • Climate solutions companies and project developers at all stages of development, from early-stage spinouts and start-ups through to commercially mature businesses. The FCA says it found a set of system-level challenges that affect how efficiently capital is matched to opportunity. The FCA identifies three main challenges: 1. Some climate solutions struggle to reach a commercial maturity sufficient to attract private capital. 2. Capital is not always well-matched to opportunity, despite strong appetite. 3. Information and capacity gaps create frictions. The FCA says it is sharing its findings with UK and international stakeholders to inform policy development andmarket coordination. The FCA says it will continue to advance its broader sustainable finance work to strengthen market integrity, transparency and trust, including supporting the development of industry-led transition metrics through the Climate Financial Risk Forum.