Insider disclosure rules by country: deadlines, thresholds and how filings compare

Why insider disclosure rules do not travel

Every developed market makes company insiders disclose when they buy or sell their own stock. That is where the agreement ends. Who counts as an insider, what has to be reported, how fast, above what size, and where the record lands are all set market by market. A trade that is public in the United States two business days after execution might not surface in Canada for another few days, and in Japan or Korea it might not surface as a trade at all, only as a change in a holdings report once the position crosses 5 percent.

This index is the map. It links a definitive guide for each of the ten regimes we track most closely, and it flags the handful of reading traps that apply no matter which market you are looking at. If you only remember one thing: never compare a raw filing count or a raw deadline across two countries without checking what the filing actually is.

The map: ten regimes at a glance

The deadline column is the single most misread field in the table. "5 days" means calendar days in Canada and business days in Japan and Korea. "3 days" is working days in the UK, trading days in France, business days under the wider MAR text. Those distinctions decide whether a Friday trade is late on Monday or the following Wednesday.

The MAR family: one rulebook, national dials

Four of the ten regimes are the same regulation wearing different national clothes. Article 19 of the EU Market Abuse Regulation defines persons discharging managerial responsibilities (PDMR) and the people closely associated with them, sets a three business day notification clock, and imposes a 30 day closed period before results. Start with the MAR Article 19 guide for the shared machinery.

Then each country adds its own layer. France wires MAR into the Code monetaire et financier and publishes in the BDIF database, and raised its de minimis threshold to EUR 50,000 at the end of 2025: see the AMF insider declarations guide. Germany runs MAR through the Wertpapierhandelsgesetz with BaFin as the competent authority, covered in the BaFin directors' dealings guide. The United Kingdom froze EU MAR into domestic law after Brexit and kept the old EUR 5,000 threshold that the EU has since abandoned, explained in the FCA PDMR notifications guide. Same skeleton, four different thresholds, four different databases.

Browse the live output on the French, German and UK market hubs.

The Americas: the fastest tape in the world

The United States sets the pace everyone else is measured against. Section 16 of the Securities Exchange Act makes directors, officers and beneficial owners of more than 10 percent file Form 4 before the end of the second business day after a trade, straight into EDGAR as structured XML. Nothing in any other major market is that fast. The SEC Form 4 guide covers the transaction codes, the Rule 10b5-1 plan checkbox, and why activist funds crossing 10 percent are noise rather than signal.

Canada runs a single electronic insider report on SEDI, with a five calendar day clock for changes and ten for the initial filing. It is a few days slower than the US and, crucially, counts calendar days rather than business days, a distinction the regulator itself lists as the most common filing error. The SEDI filing guide has the details. Live data sits on the US and Canada market hubs.

Asia-Pacific: holdings, not trades

This is where the word "insider filing" changes meaning. Japan's EDINET does not carry a per-executive trade form. Its insider-relevant public record is the large shareholding report, triggered when a holder crosses 5 percent of a company and filed within five business days, with change reports on every 1 percent move. The typical filer is an asset manager or bank, not a founder. The EDINET guide explains the structure. Korea's DART, run by the Financial Supervisory Service, combines executive and major-shareholder ownership reports with the same 5 percent large-holding regime; see the DART guide.

Australia runs two parallel tracks: director interest notices (Appendix 3X, 3Y, 3Z) filed by the listed entity within five business days, and substantial holder notices (Forms 603, 604, 605) on crossing or moving through 5 percent within two business days. The ASX guide shows how vesting and lapse of performance rights masquerade as trades. India layers two SEBI regimes: the Prohibition of Insider Trading (PIT) Regulations, under which promoters, directors and designated persons disclose trades above Rs 10 lakh in a quarter within two trading days, and the SAST takeover code for 5 percent and 2 percent acquisition moves. The SEBI guide untangles the two. Explore the Japan, Korea, Australia and India hubs.

Traps that cross every border

Five reading errors recur in every market, and they are the difference between a signal and a mirage.

• Thresholds are floors, not caps. A de minimis exemption means small trades below the line are not reported. Once the running total for the period crosses it, every later trade counts, however small. The exemption never caps how much can be disclosed.
• Gifts, inheritances and awards print at zero or nil. These are notifiable non-market transfers, not data errors, and say nothing about what an insider would pay.
• Option exercises come in pairs. The exercise and the sale of the resulting shares are two separate rows for one economic event. Counting both double counts a single decision.
• Closed periods bunch the calendar. Most regimes ban trading in the weeks before results, so insider buying clusters just after earnings. A post-results burst is often the calendar, not a coordinated signal.
• Institutions are "insiders" too. Index funds and asset managers crossing a 5 or 10 percent line file the same reports as founders. Their filings are portfolio mechanics, not operating knowledge. Role filtering matters as much as transaction filtering.

How insiders-trades.com unifies 28 regulators

We ingest all of these regimes into a single declaration model, normalising roles across 28 regulators (a directeur general, a CEO and a dapyo isa land in the same bucket) and converting every amount to EUR for cross-market comparison. Fast structured feeds like SEC Form 4 and slow PDF-bodied filings like the AMF declarations end up in the same shape, which is what makes a genuine cross-country comparison possible in the first place.

Each country guide in this series documents exactly what we pull, from where, and with what freshness baseline. Use this index as the entry point, then drop into the market hub or the specific guide for the jurisdiction you care about.