Regarding the above infringements, the summary of the MAR sanctions below is limited to administrative sanctions. It does not include, for example, illegal insider trading, which carries significantly more severe consequences, including criminal prosecution for financial crimes under national law. Such sanctions include:
- Withdrawal of Authorisation: The withdrawal of the authorisation of an investment firm.
- Public Warning: A public warning indicating the person responsible for the infringement and its nature.
- Cease and Desist Order: A cease and desist order for the person responsible for the infringement to prevent repeating that conduct.
- Temporary or Permanent Ban: A temporary or permanent ban of a PDMR within an investment firm (or any other natural person), who is held responsible for the infringement from exercising management functions in investment firms.
- Temporary Ban from Dealing on Own Account: A temporary ban of a PDMR within an investment firm (or another natural person), who is held responsible for the infringement, from dealing on its account.
- Disgorgement of Profits: Disgorging profits gained due to the infringement.
- Maximum Administrative Pecuniary Sanctions: At least 3 times the profits gained due to the infringement.
Pecuniary Sanctions for Natural Persons
- EUR 5,000,000 for Art. 14 or 15 infringements.
- EUR 1,000,000 for Art. 16 or 17 infringements.
- EUR 500,000 for Art. 18, 19, or 20 infringements.
Pecuniary Sanctions for Legal Persons
- EUR 15,000,000 or 15% of the total annual turnover for Art. 14 or 15 infringements.
- EUR 2,500,000 or 2% of the total annual turnover for Art. 16 or 17 infringements.
- EUR 1,000,000 for Art. 18, 19, or 20 infringements.
Manage PDMR requirements effortlessly—book a demo now to streamline your compliance with Logwise.
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 […]
