Notice: Amendments to the EU Benchmarks Regulation Effective 1 January 2026

Solactive AG (“Solactive”), a registered benchmark administrator under Regulation (EU) 2016/1011 (the “Benchmarks Regulation”), hereby informs stakeholders of forthcoming amendments to the regulatory framework governing benchmarks in the European Union. These changes, adopted as part of the European Commission’s review of the Benchmarks Regulation, will enter into force on 1 January 2026.

Summary of Regulatory Developments

The revised Benchmarks Regulation introduces a more proportionate and risk-based supervisory regime, with the following key implications:

• Refined Scope of Application: The revised framework limits the scope of the regulation to critical and significant EU benchmarks, EU Paris-aligned benchmarks (PABs) and EU Climate Transition benchmarks (CTBs). As a result, non-significant benchmarks will no longer fall within the direct scope of the regulation.
• Third-Country Benchmark Access: The amendments streamline the regime for the use of third-country benchmarks by EU-supervised entities, focusing regulatory oversight on benchmarks deemed relevant to the EU financial system.
• Reduced Compliance Burden: The revised regulation aims to alleviate administrative and compliance obligations for administrators of non-significant benchmarks, while maintaining the integrity and reliability of benchmarks used within the EU.
• Adjustment of ESG Transparency Requirements: Adjusted disclosure obligations now apply to all benchmarks provided by administrators subject to the Benchmarks Regulation and marketed with ESG characteristics, regardless of their regulatory classification. This ensures that users of ESG-labelled benchmarks have access to consistent, transparent, and comparable information.

These changes are set out in Regulation (EU) 2025/914 of the European Parliament and of the Council of 7 May 2025, amending Regulation (EU) 2016/1011 (Regulation (EU) 2025/914 of the European Parliament and of the Council of 7 May 2025).

Implications for Solactive’s Benchmarks

Solactive currently administers a suite of benchmarks, including:

• Non-significant benchmarks,
• Paris-aligned benchmarks (PABs), and
• Climate Transition benchmarks (CTBs)

In light of the revised regulatory framework:

• Solactive’s PABs and CTBs will remain subject to the full requirements of the Benchmarks Regulation.
• Solactive’s non-significant benchmarks will no longer be subject to direct regulatory supervision under the Benchmarks Regulation as of 1 January 2026. Nevertheless, Solactive will continue to apply robust governance and control frameworks to these benchmarks, consistent with industry best practices and the IOSCO Principles for Financial Benchmarks.

Frequently Asked Questions (FAQs)

Q1: Will any of Solactive’s benchmarks be discontinued as a result of the regulatory changes?

A: No. All existing benchmarks will continue to be maintained. The regulatory classification of certain benchmarks will change, but their availability and methodology will remain unaffected.

Q2: Will the governance or methodology of non-significant benchmarks change?

A: While these benchmarks will no longer be subject to direct supervision under the Benchmarks Regulation, Solactive will continue to apply rigorous governance and oversight in line with the IOSCO Principles.

Q3: Will the regulatory status of benchmarks affect their availability or licensing terms?

A: No. All benchmarks currently provided by Solactive will remain available. Licensing terms remain unchanged unless otherwise communicated.

Q4: Do I need to take any immediate action as a user of Solactive benchmarks?

A: No immediate action is required for continued use of Solactive’s benchmarks. However, we recommend reviewing your governance on benchmark use and documentation to ensure alignment with the revised regulatory classifications effective 1 January 2026.

Q5: How can I verify whether a benchmark remains within the scope of the Benchmarks Regulation?

A: The regulatory classification of each benchmark (e.g. non-significant benchmark, Paris-aligned benchmarks, Climate Transition benchmarks) is clearly indicated in the benchmark statement available on Solactive’s website. Benchmarks remaining within the scope of the Benchmarks Regulation will be included in the register of benchmarks maintained by ESMA after 1 January 2026.

Q6: What happens if I use a benchmark that is no longer regulated under the Benchmarks Regulation?

A: You may continue to use such benchmarks. However, you should assess whether your internal policies or regulatory obligations require the use of regulated benchmarks or additional due diligence.

Q7: Are there any changes to ESG-related benchmarks I should be aware of?

A: Yes. Under the revised regulation, all benchmarks provided by benchmarks administrators in the EU and marketed with ESG characteristics — regardless of whether they remain within the regulatory scope — must meet enhanced transparency and disclosure requirements. This includes clear and accessible information on ESG factors, methodologies, and alignment with sustainability objectives. Solactive remains fully committed to meeting these disclosure and transparency requirements across its entire suite of ESG-labelled benchmarks and will continue to provide comprehensive, high-quality documentation in line with the Benchmarks Regulation.

Q8: Will Solactive benchmarks continue to align with international standards?

A: Yes. Even for benchmarks no longer subject to the Benchmarks Regulation, Solactive will in general maintain alignment with the IOSCO Principles for Financial Benchmarks and apply robust governance and oversight practices.

Q9: Who can I contact for further information or if I need benchmark classification details for regulatory reporting or internal compliance?

A: Please contact our Compliance team at compliance@solactive.com.