Global Trustee and Fiduciary Services Bite-Sized Issue 6 2026

18 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 ESMA Advances the Simplification of EU Reporting Frameworks for Funds and Transactions On 4May 2026, ESMA launched a harmonised approach to funds reporting, with the aimof setting a clear path towards streamlined, more efficient transaction reporting across Europeanmarkets. ESMA says the two reports that comprise the approach are complementary pillars of ESMA’s broader simplification and burden reduction agenda, launched last year. Final Report on the integrated collection of funds’ data In the report, ESMA sets out a strategic move away from fragmented national reporting towards a common EU reporting framework, centred on a common and single reporting template designed to remain proportionate for different fund sizes and investment strategies, while meeting supervisory needs. The aim is to reduce duplication, improve data consistency and enhance the usability of data for authorities. To support this approach, ESMA outlines a hybrid operational model, under which data validation, storage and analytics would be organised at EU level, while data collection would remain at national level. By facilitating data sharing across authorities, the centralised hub will offer efficiency gains not only for authorities but will also contribute further to burden reduction by limiting duplicative data requests. Next steps on funds reporting include the development of regulatory and implementing technical standards (RTS/ITS), that will be presented next year. After that, the implementation of the new template and the rest of recommendations will be gradually introduced, with the first phase focusing on the integration of reporting under AIMFD and UCITS, and the second phase that would expand the integrated framework to other reporting obligations. Interim report on the holistic review of transaction reporting Based on the feedback received frommore than 100 respondents to the previous call for evidence on transaction reporting simplification, ESMA says it has identified the main challenges in the current reporting frameworks, and the most promising approaches to overcome them: instrument‑based and dual-side simplifications and the implementation of a “report once” framework across EMIR, MiFIR and SFTR in the long term. ESMA says that most respondents indicated that overlapping and inconsistent reporting requirements, frequent and unsynchronised regulatory changes, fragmented reporting channels and dual reporting are major drivers of cost and complexity. Considering the need to perform a thorough cost-benefit analysis, the report does not contain policy recommendations yet. As part of the next steps, ESMA says it will further engage with markets participants, including through an open hearing held on 28 May 2026, before moving forward with final recommendations to be published by mid-year. Link to Final Report on the Integrated Collection of Funds’ Data here Link to InterimReport on the Call for Evidence on a Comprehensive Approach for the Simplification of Financial Transaction Reporting here LUXEMBOURG Repeal of Circular IML 91/75 On22May 2026, theCommissiondeSurveillance duSecteur Financier (CSSF) publishedaCommuniqué highlighting the publication of Circular CSSF 26/912 concerning the repeal of Circular IML 91/75. The CSSF says that since the publication of Circular IML 91/75, the legal framework applicable to undertakings for collective investment (UCIs) has significantly evolved: several laws on UCIs have been enacted, and new legislation relating to alternative or non-alternative funds (SICARs and SIFs) has been adopted. In addition, EU regulation has further complemented the regulatory framework. The CSSF says that the evolution of standards applicable to UCIs has gradually led to the repeal and replacement of several chapters of Circular IML 91/75 by other circulars. Furthermore, several rules from Circular IML 91/75 are now integrated into the CSSF’s administrative practice. As a result, Circular IML 91/75 is repealed with effect from 22 May 2026 . Link to Circular CSSF 26/912 here