ESMA · ESMA_QA_1735 Answer Published

Types of transactions by PDMRs prohibited during closed periods

Regulation
Market Abuse Regulation (MAR) Regulation (EU) No 596/2014 - Market Intergrity
Topic
Managers' transactions
Submitted
2017-11-21
Answered
2017-11-21
More Q&As on this regulation →

Question

Are the types of "transaction" by a PDMR prohibited during a closed period under Article 19(11) of MAR the same as those types of transaction subject to the notification requirements set out under Article 19(1) of MAR?

Answer

[ESMA70-145-111 MAR Q&A, Q&A 7.9] Yes. It is pointed out that Article 19(11) of MAR only applies to a PDMR when conducting transactions on its own account or for the account of a third party whereas the notification of transactions required under Article 19(1) of MAR also applies to persons closely associated to a PDMR.
View original on European Securities and Markets Authority ↗

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.

Similar Q&As

Trading during closed periods and prohibition of insider dealing

Answered 2017-11-21

Application of the prohibition contained in Article 19(11) MAR to issuers

Answered 2018-11-12

Scope of the exception in Article 19(12a) of MAR to PDMRs’ general prohibition to trade during the closed period

Answered 2025-08-01

Application of a new exception to PDMRs’ general prohibition to trade during the close period

Answered 2026-02-18

Threshold calculation

Answered 2016-12-20

More Q&As on this topic

Application of a new exception to PDMRs’ general prohibition to trade during the close period

Answered 2026-02-18

Scope of the exception in Article 19(12a) of MAR to PDMRs’ general prohibition to trade during the closed period

Answered 2025-08-01

Application of the prohibition contained in Article 19(11) MAR to issuers

Answered 2018-11-12

Trading during closed periods and prohibition of insider dealing

Answered 2017-11-21

Closely associated persons under Article 3(1)(26)(d) of MAR

Answered 2017-07-06

📋 Track EU financial regulation continuously

Forseti monitors EU financial regulation and delivers personalised alerts anchored to verified official sources.

Start free trial → Learn more

14-day free trial. No credit card required.