Top 7 requirements of insider lists

Issuers (or anybody operating on their behalf or for their account) must compile a list of all insiders who work for them under contract or otherwise have access to inside information (such as lawyers, accountants, investment banks, or other advisers).

Insider lists must have deal-specific or event-based sections and can also have an optional permanent insider section (Article 2, Implementing Regulation).

Insider lists must include all content specified by MAR (Article 18(3)) and be drawn up using the prescribed template (MAR, Article 2(3)).

Issuers must take all reasonable steps to ensure insiders acknowledge their duties in writing (MAR 18(2)).

Insider lists must be maintained in electronic form (Article 2(3), Implementing Regulation) and updated immediately (including when the basis for adding a person changes) (Article 18(4), MAR).

An issuer must promptly disclose an insider list to the relevant National Competent Authority upon request (MAR 18(1)c).

Insider lists must be kept for at least five years after they are created or amended (Article 18(5), MAR).

Learn more

Top 7 requirements of insider lists

Discover the key requirements of insider lists, as defined by UK and EU Market Abuse Regulation

What is the correct format for an insider list?

Learn how to format your insider list, and the difference between project and permanent insiders

What information should an insider list contain?

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

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