ESMA · ESMA_QA_1749 Answer Published

Subject of the insider list requirements

Regulation
Market Abuse Regulation (MAR) Regulation (EU) No 596/2014 - Market Intergrity
Topic
Insider lists
Submitted
2017-09-01
Answered
2017-09-01
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Question

Are persons acting on behalf or account of the issuer (e.g. advisors and consultants) subject to the obligation to draw up, update and provide to the NCA upon request their own insider list under Article 18(1) of MAR?

Answer

[ESMA70-145-111 MAR Q&A, Q&A 10.1] Yes, the legislative aim of the insider list regime under MAR is to cover any person that, by virtue of its action on behalf or account of the issuer, has access to inside information. Therefore, not only the issuer but also all the persons acting on behalf or account of the issuer that have access to inside information relating to the issuer (e.g. advisors and consultants) are subject to the obligation to draw up, update and provide to the NCA upon request their respective insider list under Article 18 of MAR.
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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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