Global Trustee and Fiduciary Services Bite-Sized Issue 6 2026

15 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 • Record keeping; • Target market assessment for products with sustainability-related objectives; and finally • Assessment of the ‘negative’ target market for products that do not consider sustainability factors. ESMA says it reaffirms the importance of sustainability and encourages firms to continue implementing the MiFID II sustainability requirements, recognising that the CSA has been conducted at a time when the sustainable finance framework is undergoing significant revision. ESMA says that, in view of these developments, and reflecting its strategic priority of promoting simplification and reducing undue burden, it invites national competent authorities to adopt a proportionate supervisory approach. This includes fostering dialogue with firms during the transition period, rather than prioritising enforcement actions, without prejudice to cases involving clear breaches or mis‑selling. Link to Statement here T+1 ESMA Consults on Revised Guidelines to Support Smoother Allocations and Confirmations Under T+1 On 26 May 2026, the European Securities and Markets Authority (ESMA) launched a consultation on the updated guidelines on standardised procedures and messaging protocols. This review is part of ESMA’s work to support market participants in preparing for the transition to a T+1 settlement cycle. ESMA says the updates are designed to make post trade communication faster, clearer and more consistent across the EU. They reflect the amendments proposed in ESMA’s Final Report on Amendments to the RTS on Settlement Discipline and support firms in meeting tighter timelines further to the transition to T+1. Key changes include: • Reflecting the mandatory use of electronic, standardised communication channels and international messaging standards; and • Removing references to non-electronic and non-machine-readable communication methods, such as oral allocations and confirmations, except in cases of temporary technical disruptions. ESMA says the revised guidelines should apply from 7 December 2026 , in alignment with the expected date of application of the proposed new requirements for allocations and confirmations under the RTS on Settlement Discipline. ESMA says the consultation comes ahead of the RTS’s formal endorsement by the European Commission, to give stakeholders adequate time to submit their feedback and prepare for implementation. ESMA reiterates the importance of preparing for the upcoming regulatory transition to T+1 settlement, which will take effect on 11 October 2027 . Market participants are urged to continue their preparations to meet the new requirements ahead of the deadline. Stakeholders are invited to submit feedback by 7 July 2026 . ESMA will then consider the feedback received and expects to publish the final report including updated guidelines by October 2026 . Link to Consultation here