Global Trustee and Fiduciary Services Bite-Sized Issue 6 2026

14 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 Commission Seeks Feedback on Revised Sustainability Reporting Standards On 6 May 2026, the European Commission (Commission) launched a one‑month “Have‑Your‑Say” public feedback on draft final versions of revised European Sustainability Reporting Standards (ESRS) and a voluntary reporting standard for smaller companies. These standards aim to cut administrative burden for EU businesses while preserving the quality of sustainability disclosures. They build on the Omnibus I simplification package, which streamlines sustainability reporting in the EU and reduces the number of companies in scope of the Corporate Sustainability Reporting Directive (CSRD). It is stated that the draft revised ESRS reduce mandatory datapoints by over 60% and total datapoints by over 70% as there . The new ESRS are shorter and clearer, introduce new flexibilities for companies, and simplify the materiality assessment used to determine what must be reported. Overall, the Commission says these changes are expected to reduce reporting costs per company by more than 30%. The revised ESRS largely build on technical advice from the European Financial Reporting Advisory Groups (EFRAG), the Commission’s independent multi‑stakeholder advisory body on reporting standards. Stakeholders fed into EFRAG’s work in spring 2025, followed by a public consultation on EFRAG’s first draft in summer 2025. The Commission is proposing targeted adjustments to EFRAG’s advice to further ease the reporting burden without undermining the CSRD’s policy objectives. Whilst it is proposed that the revised ESRSs will apply to CSRD reporting for financial years beginning on or after 1 January 2027, a key aspect of the Commission’s proposal at this stage includes allowing reporters to apply the revised ESRSs, if they wish, to CSRD reporting for financial years beginning between 1 January 2026 through 31 December 2026 (an option which is stated to assist with the reporting burden for reporters). The draft voluntary standard is consulted on pursuant to the European Commission’s mandate to establish this standard as a result of Omnibus changes which enacted a “value chain cap” for sustainability reporting, i.e., CSRD in‑scope companies cannot require value‑chain partners with 1000 employees or fewer to provide information beyond what is set out in the voluntary standard. The draft voluntary standard is based on EFRAG’s 2024 voluntary SME standard (VSME), which the Commission endorsed through a recommendation in 2025. The consultation period closed on 3 June 2026 . The Commission says it will adopt the two delegated acts as soon as possible after the consultation closes. They will subsequently be transmitted to the European Parliament and the Council for scrutiny under the no‑objection procedure (two months, extendable by a further two months at the request of either institution) before entering into force. Link to Revised European Sustainability Reporting Standards (ESRS) here Link to Draft Voluntary Reporting Standard for Smaller Companies here ESMA Promotes Proportionate Supervision of MiFID II Sustainability Requirements On 6 May 2026, the European Securities and Markets Authority (ESMA) issued a statement presenting the results of its Common Supervisory Action (CSA) on how sustainability is integrated into firms’ suitability assessment as well as into processes and procedures for product governance. ESMA says that overall, the assessment of the national reports indicates that firms have continued to make progress in integrating the MiFID II sustainability requirements into their suitability and product governance processes, but at the same time, the CSA also confirms that practices remain uneven across firms and jurisdictions, and that further improvements are needed in several areas such as: • Information to clients about the purpose of the suitability assessment and its scope; • Arrangements necessary to understand clients, investment products, and ensure the suitability of an investment; • Adaptation of clients’ sustainability preferences;