Global Trustee and Fiduciary Services Bite-Sized Issue 8 2026

14 AIFMD CRYPTOASSETS EMIR FINTECH IOSCO MIFID II/MIFIR OPERATIONAL RESILIENCE SUSTAINABLE FINANCE/ESG T+1 ASIA PACIFIC EUROPE NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 8 | 2026 Quick Links CSSF Publishes Communication to Market Participants on the Application of the ESG Ratings Regulation and the newDisclosure Requirements Under the SFDR On 1 July 2026, the CSSF published a communiqué drawing the attention of market participants to the fact that Regulation (EU) 2024/3005 of the European Parliament and of the Council of 27 November 2024 on the transparency and integrity of Environmental, Social and Governance (ESG) rating activities (the ESG Ratings Regulation) applies from 2 July 2026. The CSSF stated that the ESG Ratings Regulation introduces a new disclosure requirement under Article 49, which amends Article 13 of Regulation (EU) 2019/2088 on sustainability related disclosures in the financial services sector (the SFDR). When financial market participants and financial advisers in scope of the SFDR issue and disclose to third parties an ESG rating as defined in Article 3, point (1) of the ESG Ratings Regulation, as part of their marketing communications, they shall include on their website the same information as required by point 1 of Annex III of the ESG Ratings Regulation. Financial market participants and financial advisers shall disclose in those marketing communications a link to the website disclosures. The CSSF stated that it expects financial market participants and financial advisers to duly comply with the above‑mentioned provisions as from 2 July 2026. The CSSF states it will continue to monitor ongoing regulatory developments within the EU regarding the SFDR and will adopt a proportionate approach in its supervisory practices, ensuring that both the scope and intensity of supervisory actions take into consideration the remaining uncertainties and potential evolution of the regulatory landscape. The CSSF further highlights the public statement published by ESMA (above) which clarifies that, from 2 July 2026 and until 2 November 2026, third parties may continue publishing or distributing ESG ratings issued by existing, but still unauthorised, ESG rating providers that have notified ESMA of their intention to continue operating in the Union, until ESMA has adopted a decision to grant or refuse the relevant authorisation, recognition or registration, as applicable. Link to CSSF Communique here T+1 T+1 Detail Rules are Known: Getting Started with the Preparations On 27 July 2026, the Dutch Authority for the Financial Markets (AFM) published a newsletter detailing the progress it has made to transitioning to a T+1 settlement cycle. On 11 October 2027, financial markets in the European Union will move to a T+1 resolution cycle. The European Commission has adopted the detailed rules for this transition. As a result, the AFM is asking market participants to continue – or start – with T+1 preparations. The AFM says that firms that start T+1 preparations too late run the risk of operational disruptions, higher costs and reputational damage. As a result, market participants are urged to actively prepare and, where necessary, to accelerate their preparations. The newsletter covers: • What is the transition to T+1?; • The rules for the transition to T+1; • The first important deadline is 7 December 2026; • On 11 October 2027, T+1 will start across the EU; and • The AFMasksmarket participants to actively prepare and accelerate preparations where necessary. More information can be found in the detailed rules for T+1 and the publications of the EU T+1 Industry Committee and ESMA. Link to Newsletter here