ESMA · ESMA_QA_1734 Answer Published

Trading during closed periods and prohibition of insider dealing

Regulation
Market Abuse Regulation (MAR) Regulation (EU) No 596/2014 - Market Intergrity
Topic
Managers' transactions
Submitted
2017-11-21
Answered
2017-11-21
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Question

How should permission to trade in a closed period, which may be granted in certain circumstances to PDRMs in accordance with Article 19(12) of MAR, be considered in the context of Article 14 of MAR?

Answer

[ESMA70-145-111 MAR Q&A, Q&A 7.8] The insider dealing prohibition contained in Article 14 of MAR applies during closed periods referred to in Article 19(11) of MAR in the same way as it does at any other time, and must therefore be complied with by PDMRs. This means that when an issuer allows a PDMR to trade under Article 19(12) of MAR, the general insider dealing provisions still apply and the PDMR must always give consideration as to whether or not the relevant transaction would constitute insider dealing.
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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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