Topic Information obligations for issuers Threshold
Article from Issuer Guidelines published by the Federal Financial Supervisory Authoritiy
“Own account transactions” by the person concerned within a calendar year are subject to the notification obligation as soon as they reach a total amount of €5,000 by the end of the calendar year. Under Article 19(9) of the MAR, the competent authority can increase this threshold to €20,000. BaFin increased the threshold of €5,000 to €20,000 by means of a general administrative act effective 1 January 2020. ESMA has published a list of applicable thresholds1 on its website. To calculate the threshold, the transactions of the person discharging managerial responsibilities and persons closely associated with that person discharging managerial responsibilities do not have to be added up.2 If this group of persons carries out a transaction that will reach the threshold in the calendar year, only the transaction that reaches the threshold and all subsequent transactions have to be notified.
Acquisition and disposal transactions may not be offset.
See sections II.3.9.12 and II.3.9.13 for guidance on calculating the threshold for gifts, donations and inheritances.
There is no legal obligation to also notify transactions lower than the threshold, although this is technically possible.
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