The issuer must keep a list of all PDMRs (Persons Discharging Managerial Responsibilities) and PCAs (Persons Closely Associated). This requirement is separate from the insider logbook obligations.

List Format and Content Requirements Copied

  • There is no requirement for a special format for the list.
  • The list must include:
    • (a) The name and appropriate position of each PDMR.
    • (b) The names and business names of their PCAs, clearly indicating who is associated with whom.

Issuer Responsibilities Regarding PDMRs and PCAs Copied

The list of PDMRs and PCAs is not public.

It is not the responsibility of the issuer to verify the association or whether individuals have been notified.

The issuer is also not responsible for taking action regarding transaction notifications received by the issuer.

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EU Listing Act – Implications for MAR and Insider Lists

EU Listing Act – Implications for MAR and Insider Lists

The Act was published 14 November 2024 and entered into force on 4 December 2024. Its changes to MAR are rolled out in two waves, with two different effective dates: 4 December […]


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EU Listing Act – Implications for MAR and Insider Lists

EU Listing Act – Implications for MAR and Insider Lists

The Act was published 14 November 2024 and entered into force on 4 December 2024. Its changes to MAR are rolled out in two waves, with two different effective dates: 4 December […]


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EU Listing Act – Implications for MAR and Insider Lists – 4 December 2024

EU Listing Act – Implications for MAR and Insider Lists – 4 December 2024

The Act was published 14 November 2024 and entered into force on 4 December 2024. Its changes to MAR are rolled out in two waves, with two different effective dates: 4 December […]


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Revised Conditions for Delaying Disclosure

Revised Conditions for Delaying Disclosure

The delay mechanism (under Art. 17(4)) is retained, but one of the three conditions has been amended. The previous condition – that delay is “not likely to mislead the public” – is […]


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Protracted Processes: Disclosure Only on the Final Event

Protracted Processes: Disclosure Only on the Final Event

Under the pre-June 2026 rules: Issuers have been required to disclose inside information arising at each intermediate step of a protracted process (such as e.g. ongoing merger negotiations, a capital raise, or […]


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