Global Trustee and Fiduciary Services Bite-Sized Issue 8 2026

4 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 • Stablecoins, including concerns related to the dominance of USD denominated stablecoins; and • Cross-cutting considerations, including the need for interoperability in digital finance, development of the digital euro, and the EU’s dependence on non-EU service providers for DLT infrastructure. Link to the Resolution here EMIR ESMA Publishes Technical Standards on CCP Admission Criteria Elements On 8 July 2026, the European Securities andMarkets Authority (ESMA) published its Final Report on the Regulatory Technical Standards (RTS) concerning the central counterparties’ (CCPs) admission criteria elements, following the review of the EuropeanMarket Infrastructure Regulation (EMIR 3). EMIR 3 introduces amendments to the provisions on participation requirements in CCPs, including for non-financial counterparties (NFCs). The RTS specify the elements which CCPs should consider when establishing their admission criteria for clearing members. This includes considerations related to NFC clearing members and sponsored membership models. The RTS do not set the actual admission criteria but instead define the elements for CCPs to consider. ESMA conducted a public consultation on the draft RTS in the last quarter of 2025 and held a public hearing in November 2025. The Final Report considers the feedback received during this process. The RTS will now be submitted to the European Commission for endorsement, following which they will be subject to scrutiny by the European Parliament and the Council. Link to Final Report here ESMA Publishes Preliminary Findings on the Active Account Requirement and the First Annual Report of the Joint Monitoring Mechanism On 6 July 2026, ESMA published the Interim Report of the Effectiveness of the Active Account Requirement and the First Annual Report of the Joint Monitoring Mechanism. Preliminary findings on the Active Account Requirement Based on available data, analytics and industry feedback, the Interim Report provides preliminary findings on the Active Account Requirement (AAR) implementation during 2025 and early 2026. ESMA says the preliminary findings show that: • As of February 2026, around 500 entities had notified ESMA and national competent authorities that they are subject to the AAR. • These entities represent a significant share of EU activity in relevant derivatives markets, with more than 90% of notional outstanding held by EU entities in the scope of the requirement. • Notifications are spread across most Member States, with particularly strong representation in France, Germany and the Netherlands, and banks accounting for around half of notifying entities. • In terms of impact, the report identifies early signs of increased clearing activity at EU central counterparties (EU CCPs), particularly among smaller entities, with some entities fully relocating their positions to the EU. • The findings also point to a gradual, but limited, shift inmarket shares from systemically important third-country central counterparties (Tier 2 CCPs) to EU CCPs in certain AAR-related products. Joint Monitoring Mechanism – Supporting coordinated cross sectoral oversight of the EU clearing landscape Together with the AAR interim report, ESMA has also published the first Annual Report of the Joint Monitoring Mechanism (JMM), which plays a key role in monitoring developments and assessing financial stability risks across EU CCPs, clearing members and clients.