Topic Information obligations for issuers Format and structure
Article from Issuer Guidelines published by the Federal Financial Supervisory Authority
The insider list must be managed electronically using the format for template 1 or 2 in Annex 1 of Commission Implementing Regulation (EU) 2016/347. SME issuers are not required to manage the list in an electronic format, but they must choose a format that ensures that the completeness, integrity and confidentiality of the information are maintained during the transmission.
The insider list must be divided into separate sections, with each information allocated to a separate section that only contains details of the natural persons who have access to the inside information relevant to that section (Article 2(1) of Commission Implementing Regulation (EU) 2016/347). What this means is that the previous option to draw up insider lists by functions within the company is no longer available.
Alternatively, the insider list can be supplemented by a section listing “permanent insiders” to avoid having to include these persons in each individual insider list. Persons should only be included in the “permanent insiders” section if they have access at all times to all inside information due to the nature of their function or position (see recital (4) of Commission Implementing Regulation (EU) 2016/347).
