The notification obligation applies to all “own account transactions“ conducted by the person discharging managerial responsibilities or a person closely associated with that person discharging managerial responsibilities

• relating to share or debt instruments of the issuer that are traded on a regulated market on the application or with the approval of the issuer or, if they are only traded on an MTF/OTF, if the issuer has had them approved, or if the issuer has applied for them to be admitted to trading on an MTF (points (a) to (c) of Article 2(1) in conjunction with Article 19(4) of the MAR),
• or in derivatives or other financial instruments linked to them (point (d) of Article 2(1) of the MAR), or
• in the case of emission allowance market participants, in emission allowances, auction products based thereon or to derivatives relating to them.

Financial instruments means financial instruments defined in Section C of Annex I of Directive 2014/65/EU (see the list in section I.1).

It is not necessary for the price of the financial instrument to be directly linked to the exchange price of the issuer’s shares. This means that transactions in financial instruments that are only indirectly linked to the issuer’s shares or debt instruments are subject to the notification obligation, too.

However, in order to prevent an unreasonable expansion in the number of financial instruments subject to the notification obligation, Article 19(1a) of the MAR stipulates that only transactions in such financial instruments linked to the shares or debt instruments of the issuer are subject to the notification obligation if, at the time of the transaction, in respect of those financial instruments, the exposure to the shares or debt instruments of the issuer exceeds 20 per cent

• of the assets held by a collective investment undertaking or
• of the assets held by a portfolio of assets or
• the person discharging managerial responsibilities or the person closely associated with that person discharging managerial responsibilities knew or ought to have known the investment composition of the collective investment undertaking or the portfolio of assets, and there was reason for that manager or person to believe that the 20 per cent threshold was exceeded.