There would normally be no immediate consequences. NCAs do not perform constant controls on all companies regulated under MAR but would rather act upon specific decisions of an NCA. In case of an investigation, the NCA would most likely detect any inadequacies and, as a result, evaluate the extent of the violation and decide on appropriate sanctions to impose. Notably also, the NCAs and ESMA have developed an advanced cross-border technical cooperation standard for sanctions and measures.

MAR regulates not only which infringements are subject to certain sanctions, but also elaborates on which sanctions may be imposed upon the regulated company itself as well as upon natural persons on a case by case basis.

The sanctions for incorrect handling of the requirements for PDMRs (article 19) covers, amongst others, the following items:

MAR sanctioned infringements include failures to comply with:

EU regulation 596/2014 contains definitions and obligations:

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32014R0596