What is the correct format for an insider list?


An insider list:

  • Must include deal-specific or event-based sections; and
  • May include an optional section for permanent insiders.

All the sections above form the whole of the insider list (paragraph 285, section 8.3.4, ESMA final report).

Deal-specific and event-based sections

Issuers must divide their insider list into groups based on deals or events, with each section referring to different inside information (Article 2(1), Implementing Regulation).

Each section relates to a certain piece of inside information and should include all insiders for that event. Note that the occurrence of inside information does not necessarily correspond to a temporal or contractual event (paragraph 284, section 8.3.4, ESMA final report).

Insider lists should detail the exact pieces of inside information that insiders have access to. For example, t he information could be about a deal, a project, a corporate or financial event, or profit warnings. The insider list should be separated into sections, one for each piece of inside information. Each section should list all those with access to the same inside information (recital 3, Implementing Regulation).

Every time new inside information is identified, an additional section must be added to the insider list (Article 2(1), Implementing Regulation).

Each section must follow Template 1 in Annex I of the Implementing Regulation.

Optional section on permanent insiders

To avoid duplicate entries for the same person in several areas of an insider list, issuers may elect to create and maintain a separate section for permanent insiders.

Unlike the deal-specific or event-based parts, the permanent insiders section is not produced based on specific inside information (recital 4, Implementing Regulation). Note that deal-specific or event-based insider lists must not contain permanent insiders (Article 2(2), Implementing Regulation).

A permanent insider section must follow the Template 2 in Annex I of the Implementing Regulation.

You can download our free MAR insider list templates here.

Learn more

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What information should an insider list contain?

Our detailed guide to the types of information you must record under MAR

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