CopiedAdvisers Are Personally Responsible for The MAR Subsidiary List

MAR stipulates that persons with inside information acting on the issuer’s behalf or account must keep their own insider list.

Different Types of Insider Lists Copied

Subsidiary Insider Lists (“Sublists”): Also kept by persons acting on behalf or account of the issuer but who are performing tasks through which they have access to inside information (e.g., advisers, lawyers, accountants, or rating agencies). These individuals are responsible for keeping the sublist, which must be maintained in addition to the issuer’s insider list.

• Insider Lists: Kept by the issuers themselves (e.g., companies issuing instruments on trading venues).

• Delegated Insider Lists: Kept by persons acting on behalf or account of the issuer, assuming the task of drawing up and updating the insider list (e.g., an external company secretary or certified adviser). The issuers remain fully responsible for MAR compliance concerning keeping such insider lists.

When Should a Sublist Be Created? Copied

Is a Subsidiary List Required? Copied

A subsidiary list is required whenever individuals performing tasks for the issuer have access to inside information. These sublists serve as an extension to the issuer’s insider list.

How Does The Supervisory Authority Ensure That a Sublist is Kept? Copied

The NCA can then request that the issuer provide details regarding the insider list. The insider list will include a note indicating each person who has been asked to draw up and maintain a sublist. The format of this note may differ slightly across different EU jurisdictions.

The issuer creates an insider list.

Upon disclosure, the National Competent Authority (NCA) (i.e., the financial supervisory authority) will be notified that there has been inside information.

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