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.

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Security update: PHP2Shell vulnerabilities

Security update: PHP2Shell vulnerabilities

On 21 October 2026, two critical security vulnerabilities affecting PHP were publicly disclosed, commonly referred to as PHP2Shell (CVE-2026-109618 and CVE-2026-109619). These vulnerabilities could allow attackers to compromise affected web servers. The […]


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Security update: PHP2Shell vulnerabilities

Security update: PHP2Shell vulnerabilities

On 21 October 2026, two critical security vulnerabilities affecting PHP were publicly disclosed, commonly referred to as PHP2Shell (CVE-2026-109618 and CVE-2026-109619). These vulnerabilities could allow attackers to compromise affected web servers. The […]


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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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