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

  • Failure to create or update the list of PDMRs without delay
  • Lack of information to PDMRs with regards to MAR
  • Unnecessary delay in submitting the list to the NCA
  • Lack of information from a PDMR to their close associates with regards to MAR
  • the requirements on investment recommendations (art. 20).
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 three 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 three 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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