ESMA_QA_1749

Status: ✅ Answer Published

Link to ESMA Q&A tool: https://www.esma.europa.eu/publications-data/questions-answers/1749

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Regulatory Context

Regulation : MAR

Level 1 Regulation: Market Abuse Regulation (MAR) Regulation (EU) No 596/2014 - Market Intergrity

Level 2 Regulation: No information available

Level 3 Regulation: No information available

Topic: Insider lists

Subject Matter: Subject of the insider list requirements

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Question

Submission Date: 01 September 2017

Are persons acting on behalf or account of the issuer (e.g. advisors and consultants) subject to the obligation to draw up, update and provide to the NCA upon request their own insider list under Article 18(1) of MAR?

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ESMA Answer

Answer Date: 01-09-2017

[ESMA70-145-111 MAR Q&A, Q&A 10.1] Yes, the legislative aim of the insider list regime under MAR is to cover any person that, by virtue of its action on behalf or account of the issuer, has access to inside information. Therefore, not only the issuer but also all the persons acting on behalf or account of the issuer that have access to inside information relating to the issuer (e.g. advisors and consultants) are subject to the obligation to draw up, update and provide to the NCA upon request their respective insider list under Article 18 of MAR.

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This document was automatically extracted from the ESMA EMIR Q&A database.