ESMA · ESMA_QA_1729 Answer Published

Threshold calculation

Regulation
Market Abuse Regulation (MAR) Regulation (EU) No 596/2014 - Market Intergrity
Topic
Managers' transactions
Submitted
2016-12-20
Answered
2016-12-20
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Question

When calculating whether the threshold triggering the notification obligation under Article 19(1) of MAR is reached (5.000 EUR or 20.000 EUR), should the transactions carried out by a person discharging managerial responsibilities (PDMR) and by closely associated persons to that PDMR be aggregated?

Answer

[ESMA70-145-111 MAR Q&A, Q&A 7.3] No, the transactions carried out by a PDMR and by closely associated persons to that PDMR should not be aggregated. This involves that where the overall transactions singularly carried out by either a PDMR or any closely associated person to that PDMR do not reach the threshold, those persons should not notify those transactions even where the threshold is reached aggregating all the transactions carried out by the PDMR and all the closely associated persons to them. A practical example is a CEO buying 4.000 EUR of equity and her spouse buying another 2.000 EUR. In such a case, none of them has reached the 5.000 EUR threshold and thus a notification is not required.
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This Q&A is published by European Securities and Markets Authority and is non-binding. It does not constitute legal advice. Updated weekly from official ESA sources.

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