Topic Information obligations for issuers Dissemination of information
Article from Issuer Guidelines published by the Federal Financial Supervisory Authority
The term “information” must be interpreted very widely and covers all details and statements without any objective or content-related restriction. The concept of “information” consists not merely of verifiable facts, but also value judgements, forecasts and rumours. Examples include in particular details contained in ad hoc disclosures, notifications of own account transactions by persons discharging managerial responsibilities, voting rights notifications, annual reports and prospectuses, as well as notifications at press conferences.
It is not necessary for the information to be disseminated to the public or disclosed to a large group of persons. It is sufficient if the information is made known to a person in such a way that the information comes within that person’s control and can be noted by him or her. It does not matter how the information is disseminated. Dissemination via traditional communication channels is captured in the same way as dissemination of information via the internet, including websites, social media or anonymous blogs.
