If information already disclosed has changed to such an extent that the change is significant for its assessment by investors, the second subparagraph of Article 17(1) or (2) in conjunction with the second subparagraph of paragraph (1) of the Article requires it to be publicly disclosed. Section 4 (2) of the WpAV governs the content of this disclosure. BaFin presumes that an update is only necessary if the update has the potential to have a significant effect on prices, in other words that it itself constitutes inside information.

The updated ad hoc disclosure must contain the following information:

• In the header, a clearly highlighted title “Updated disclosure of inside information under Article 17 of Regulation (EU) No 596/2014”.
• The header must also contain a keyword that is identifiable as a subject line and summarises the main content of the disclosure.
• The issuer’s full (business) name and address.
• The International Securities Identification Numbers (ISINs) of the shares, bonds with warrants, convertible bonds and profit-participation certificates with equity-like features issued by the issuer, if they are admitted to trading on an organised market in Germany, or if such admission has been applied for; if the issuer has issued other financial instruments that have been admitted to trading or for which admission to trading has been applied for, the only information required for those financial instruments is the location of the website where the corresponding information for those financial instruments is available in a permanently updated and complete file. The homepage must contain a prominent indication of a page with information for investors where the file must be easy to find.
• The stock exchange and the trading segment for which admission to trading has been granted or applied for.
• The media to which the information was transmitted, and the date it was sent.
• Information about the changed circumstances.
• The date when the circumstances underlying the information arose.
• A short explanation about the extent to which the information directly concerns the issuer, if this is not evident from the information to be disclosed, and
• An explanation why the information would be likely to have a significant effect on the stock exchange or market price if it became publicly known, if this is not evident from the information to be disclosed.