Each transaction relating to buy-back programmes (first sentence of Article 2(3) of Commission Delegated Regulation (EU) 2016/1052) or stabilisation measures (Article 6(2) of Commission Delegated Regulation (EU) 2016/1052) must also be adequately publicly disclosed no later than by the end of the seventh trading day following the date of execution of the transaction (see point (b) of Article 1 of Commission Delegated Regulation (EU) 2016/1052). For buy-back programmes, the legislator also explicitly stipulate that the issuer must post on its website the transactions disclosed and keep that information available to the public for at least a five-year period from the date of adequate public disclosure (second sentence of Article 2(3) of Commission Delegated Regulation (EU) 2016/1052).

In terms of content, the public disclosure obligation is the same as the regular reporting obligation to the supervisory authorities. This means in particular that transactions relating to buy-back programmes must be made public in both a detailed form and in an aggregate form. However, it also appears possible that data protection considerations governing the disclosure about information on responsible natural persons could conflict with public disclosure. Because this information primarily serves the supervisory authority, it is not subject to any mandatory public disclosure obligation.

For stabilisation measures, Article 6(3) of Commission Delegated Regulation (EU) 2016/1052 stipulates that a final disclosure to the public must be made with the content specified there within one week of the end of the stabilisation period.