MAR sanctioned infringements include failures to comply with:
- The Prohibition of Insider Dealing and Unlawful Disclosure of Inside Information (Art. 14): This includes any activity related to insider trading or the improper sharing of inside information.
- The Prohibition of Market Manipulation (Art. 15): Engaging in activities designed to manipulate market prices or provide misleading impressions of financial instruments.
- The Requirements for Prevention and Detection of Market Abuse (Art. 16): This encompasses maintaining proper preventive measures and systems for detecting potential market abuse.
- Public Disclosure of Inside Information (Art. 17): Failing to disclose inside information to the public promptly and appropriately.
- Management of the Insider List (Art. 18): Issues can include:
- Failure to Promptly Create or Update an Insider List: Insider lists must be maintained accurately and updated promptly.
- Lack of Information to or from Insiders Regarding MAR: Ensuring that insiders are well-informed about their obligations and collecting necessary information.
- Missing Dates and Time-Stamps for Changes: Proper tracking and documentation of any changes to the insider list.
- Dissemination of Insider List Information to Non-Authorised Persons: Protecting insider list information from unauthorized access.
- Inadequate Archiving of Insider List and Previous Versions: Keeping comprehensive records of all versions of the insider list.
- Unnecessary Delay in Submitting Insider List to the NCA: Prompt submission of insider lists to the National Competent Authority (NCA) when required.
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 […]
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 […]
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 […]
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 […]
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 […]
