Topic Information obligations for issuers Persons required to draw up insider lists
Article from Issuer Guidelines published by the Federal Financial Supervisory Authority
Article 18 of the MAR requires two groups of people to draw up insider lists; on the one hand the issuer, and1 on the other any person acting on behalf or for the account of the issuer. These obligations exist in parallel and should not be understood as alternatives. However, the issuer can outsource management of the list to service providers, although the issuer still remains responsible for ensuring the list is properly maintained (first sentence of the second subparagraph of Article 18(2) of the MAR). For example, the parent company can also manage the list for its subsidiary, although the subsidiary as the issuer remains responsible.
The chapter is divided into the following sections:
Footnotes:
- 1 Regulation (EU) 2019/2115 of the European Parliament and of the Council of 27 November 2019 amending Directive 2014/65/EU and Regulations (EU) No 596/2014 and (EU) 2017/1129 as regards the promotion of the use of SME growth markets (“SME Growth Market Regulation”), OJ L 320, p. 1, explicitly clarifies in Article 18(1) of the MAR that the obligation applies to both groups of persons.
