UK MAR Article 19(1) requires PDMRs and PCAs to notify the issuer and the FCA "promptly and no later than three working days after the date of the transaction". Article 19(16) defines a working day as any day other than a Saturday, a Sunday, Christmas Day, Good Friday, or a bank holiday in England and Wales. Note the term: the EU text runs on "business days", the UK on "working days", and around UK bank holidays the two clocks give different answers.
The issuer's own clock changed in 2021. Originally the issuer had to publish within the same 3 business days from the transaction date, which in practice meant racing the PDMR's own deadline. Section 30 of the Financial Services Act 2021, in force since 29 June 2021, rewrote UK MAR Article 19(3): the issuer now has 2 working days from receipt of the notification. More breathing room for company secretaries, slower tape for everyone else. A trade executed on a Monday can legally surface the following Friday, roughly 5 working days later, against 2 business days for a US Form 4.
Where filings are published
A UK PDMR notification travels two roads at once:
- To the FCA: the PDMR or PCA submits the notification through the FCA's Electronic Submission System (ESS). This is the regulatory copy; it does not inform the market by itself.
- To the market: the issuer publishes an announcement through a Regulatory Information Service or Primary Information Provider, RNS being the dominant one. These are the announcements headlined "Director/PDMR Shareholding", and each embeds the standard notification template as a table.
The announcements are then archived in the FCA National Storage Mechanism (NSM) at data.fca.org.uk, the statutory store for regulated information under the Listing Rules, the DTRs, and UK MAR Articles 17 to 19. The FCA is explicit that the NSM is an archive, not a disclosure channel: "Simply having documents on the NSM does not fulfil an issuer's obligation... Issuers must use a PIP." For research purposes the direction of that sentence flips: the NSM is exactly where you go to read the record, because it holds everything, back years, in one searchable place.
How to read a notification
The UK still uses the template from onshored Implementing Regulation 2016/523, hosted in the FCA Handbook's technical standards. Every "Director/PDMR Shareholding" announcement carries the same fields:
| Field |
What it tells you |
| Name |
The PDMR or closely associated person |
| Reason for notification |
Position/status, and whether the filer is a PDMR or a PCA |
| Issuer details |
Name and LEI |
| Instrument |
Description and ISIN |
| Nature of the transaction |
Purchase, sale, award, option exercise, pledge, etc. |
| Price(s) and volume(s) |
Line by line, one row per fill or per leg |
| Aggregated information |
Combined volume and weighted price |
| Date of the transaction |
The trade date, not the announcement date |
| Place of the transaction |
Venue, or "outside a trading venue" |
Read "nature of the transaction" first, the price second. The template's free-text nature field is where a headline "purchase" reveals itself as a free share award, and where the difference between conviction and payroll lives.
Interpretation traps
Closed periods have diverged from the EU
UK MAR Article 19(11) bars PDMRs from dealing during the 30 calendar days before the announcement of an interim or year-end report. So far, identical to the EU. But the EU Listing Act relaxed some closed-period exemptions in December 2024, and the UK did not adopt those changes. Since then, conduct that is exempt in Frankfurt or Paris can still be a breach in London. Anyone applying EU-derived compliance intuitions to UK names is running on a stale rulebook; the regimes read the same and no longer are. For the EU baseline the UK froze and then diverged from, see our MAR Article 19 guide.
Aggregation hides netting
The EUR 5,000 threshold aggregates without netting, as in the EU. A PDMR who buys EUR 3,000 and sells EUR 3,000 has crossed the line, even though the net position moved nowhere. Once over the threshold, every subsequent transaction that year is notifiable, however small.
Awards and exercises look like trades
Zero-price rows are usually share awards or vesting, not open-market buying. Option exercises typically produce two rows, an acquisition at the strike and often a same-day sale at market, and the acquisition row is compensation being monetised, not a purchase decision. Pledges of shares as collateral appear in the same feed as real disposals. The template reports them all identically; only the nature field and the price separate them.
Late filing alone gets fined
The FCA's first enforcement action for a breach of UK MAR Article 19(1) was the Final Notice against Kevin Gorman on 12 December 2019. Gorman, a managing director at Braemar Shipping Services, sold shares totalling GBP 71,235.28 across three trades without notifying within the deadline. The fine was GBP 45,000 after a 30 percent settlement discount, and the notice made no finding of insider dealing. The message to filers was that the notification duty is strict; the message to data users is that UK filing dates are policed, which supports treating them as reliable event anchors.
The rules do not live where old guides say
Older UK compliance material points at DTR 3.1, the Handbook chapter that carried the pre-2016 disclosure rules. Since July 2016 the substantive obligations have sat in MAR Article 19 itself, now the onshored UK version. If a summary you are reading cites DTR 3.1 as the source of the deadline or the threshold, it predates the current regime; check the regulator's current guidance.
How insiders-trades.com tracks the UK
We ingest "Director/PDMR Shareholding" notifications from the FCA National Storage Mechanism's search API (api.data.fca.org.uk), the statutory archive, which holds roughly 98,000 PDMR documents back to 2011. The backfill pages through it by calendar month, typically 400 to 500 PDMR documents per month, and a legacy Investegate RNS scrape covers the most recent announcements ahead of their NSM appearance. Each notification is parsed into the unified declaration model: role normalised, nature of transaction mapped to buy/sell/award, and GBP amounts converted to EUR for cross-market comparison.
Browse the live output on the UK market hub, or start from a company page such as GSK, Tesco or Barclays.
Because UK MAR is onshored EU MAR, most of the mechanics here have an EU twin: see our MAR Article 19 guide for the regime the UK forked from, and the insider disclosure rules by country index for how everyone else compares.