Management Transactions and Holdings

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Obligation to notify transactions

An issuer’s managers and persons closely associated with them are obliged to notify the issuer and the FIN-FSA of their transactions relating to said issuer’s shares, debt instruments, derivatives or other financial instruments (Market Abuse Regulation, MAR, Article 19). The European Commission’s Delegated Regulation contains examples of the types of notifiable transactions. The obligation to notify transactions applies to managers (persons discharging managerial responsibilities) and persons closely associated with them.

The obligation to notify transactions applies to all transactions after a total amount of EUR 20,000 has been reached within a calendar year. Calculate the threshold by adding without netting all transactions referred to in Article 19(1) of MAR conducted within a calendar year.