Bank of New York Mellon Corp

Recent accounting developments

The following accounting guidance issued by the Financial Accounting Standards Board (“FASB”) has not yet been adopted as of June 30, 2025.

ASU 2023-09, Income Taxes (Topic 740): Improvements to Income Tax Disclosures

In December 2023, the FASB issued ASU 2023-09, Income Taxes (Topic 740): Improvements to Income Tax Disclosures, which requires a company to disclose, on an annual basis, additional disaggregated information related to the existing disclosures for the effective income tax rate reconciliation and income taxes paid.

This ASU is effective on a prospective basis, with a retrospective option, for annual periods beginning after Dec. 15, 2024, and interim periods within fiscal years beginning after Dec. 15, 2025. BNY is currently evaluating this guidance and the impact on the income tax disclosures.

Recent regulatory and other developments

For a summary of additional regulatory matters relevant to our operations, see “Supervision and Regulation” in our 2024 Annual Report. The following discussion summarizes certain regulatory, legislative and other developments that may affect BNY.

Federal Reserve Capital Rule

On April 17, 2025, the Federal Reserve proposed to revise its capital plan rule to (1) measure the SCB as the average of the CET1 capital ratio declines in the Supervisory Severely Adverse scenario, as calculated by the Federal Reserve, from the two most recent supervisory stress tests, plus four quarters of planned common stock dividends as a percentage of risk-weighted assets, subject to a 2.5% floor, and (2) extend the annual effective date of the SCB by one quarter, from October 1 to January 1, so that, following the supervisory stress test in a calendar year, new SCBs would generally be effective from January 1 through December 31 of the following calendar year. Although the proposal has not yet been finalized, the Company currently anticipates that the

proposal will not have an impact on the Company’s SCB requirement. The Company’s SCB requirement has remained at the 2.5% regulatory floor since the introduction of the SCB requirement in 2020. In June 2025, the Federal Reserve notified BNY that its preliminary SCB requirement would remain at 2.5%, equal to the regulatory floor, for the period from Oct. 1, 2025 through Sept. 30, 2026 under the current capital plan rule.

Enhanced Supplementary Leverage Ratio

On June 27, 2025, the Federal Reserve, Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation jointly proposed changes to the Enhanced Supplementary Leverage Ratio (“eSLR”), LTD and TLAC requirements. The proposed rule would: (i) recalibrate the eSLR buffer over the SLR for G-SIBs from 2% to a buffer equal to 50% of a G-SIB’s method 1 surcharge calculated under the risk-based G-SIB surcharge framework; (ii) change the eSLR requirement over the SLR for G-SIB depository institution subsidiaries from the 6% “well capitalized” threshold under the prompt corrective action framework to a buffer equal to 50% of the G-SIB parent’s method 1 surcharge calculation; (iii) amend the minimum leverage-based LTD requirement for G-SIBs to the sum of the total leverage exposure multiplied by 2.5% and the recalibrated eSLR buffer standard; and (iv) replace the 2% TLAC leverage buffer with a TLAC leverage buffer equal to the recalibrated eSLR buffer standard. BNY is assessing the potential impact of the proposal.

EU Sustainability Directives

On April 16, 2025, Directive (EU) 2025/794 (“Amending Directive”) was published in the Official Journal of the EU, which (i) delays the application dates for certain sustainability reporting obligations under Directive (EU) 2022/2464 (“CSRD”) for “second wave” companies, including four of BNY’s in-scope EU subsidiaries, by two years to 2028, and (ii) postpones the commencement date for due diligence under Directive (EU) 2024/1760 (“CSDDD”) requirements from July 26, 2027 to July 26, 2028. CSRD requires in-scope companies to disclose information about impacts, risks, and opportunities related to sustainability matters. In its current form, CSDDD will require in-scope entities to comply with sustainability-related due diligence obligations related to their operations and for their upstream chains of activities, and to adopt a transition

48 BNY plan for climate change mitigation. BNY continues to assess the impact of the timing changes set out in the Amending Directive, as well as the forthcoming simplification proposals related to CSRD and CSDDD, on its operations.

Securities and Exchange Commission (“SEC”) Withdrawal of Proposed Rules

On June 12, 2025, the SEC formally withdrew certain of its outstanding proposed rules which may have impacted BNY, including the Safeguarding Advisory Client Assets proposed amendments to the custody rules under the Investment Advisers Act of 1940. Other proposed rules withdrawn include those regarding best execution oversight, cybersecurity risk management, diligence and monitoring of third-party outsourcing by investment advisors, retail order competition, conflicts of interest associated with use of predictive data analytics, and disclosures related to environmental, social and governance investment practices. The SEC noted that it has no current intent to issue final rules with respect to the withdrawn proposed rules and will issue a new proposed rule if it chooses to pursue future regulatory action in these areas. BNY will continue to monitor developments in these areas.