Note on figures cited below. Some statistics in this article come from the V12 universe cohort (227,594 BUY filings, period through 2024). Since 2025-01-01 the live out-of-sample BUY universe (28 markets) shows a 52.96 percent win rate and a +8.59 percent mean 90-day return on 20,688 filings. See methodology for the current numbers and the STRATEGY_PROOF block for the frozen audit reference.
A filing deadline is a small number with a large personality.
Insider dealing law is one of those areas where legislators promise uniformity and then hand you sixteen local exceptions and an American cousin who insists on doing things differently.
The legal architecture for insider transaction disclosure serves two jobs at once. First, it deters abuse by forcing prompt transparency around trades by directors, executives and closely associated persons. Second, it creates a public signal for investors, researchers and journalists. Those jobs overlap, but they are not identical. A country can have strict black-letter rules and still offer miserable public access. It can also publish data promptly while imposing sanctions so rarely that deadlines become aspirational.
For this 17-market comparison, the relevant fields are practical rather than philosophical:
That sounds tidy. It is not entirely tidy.
Within the EU, the Market Abuse Regulation, MAR, especially Article 19, provides the common backbone for disclosure by persons discharging managerial responsibilities, PDMRs, and persons closely associated with them. That covers France, Germany, Italy, Spain, the Netherlands, Belgium, Norway, Finland, Denmark, Austria and Ireland. The UK retained a closely related MAR framework after Brexit, with local adaptations. Switzerland sits outside EU MAR and runs its own exchange and financial-market regime. Canada and Australia use domestic securities frameworks with different filing channels and thresholds. The US remains anchored in Section 16 of the Securities Exchange Act and SEC forms.
So yes, the table can be side by side. No, the systems are not interchangeable.
Your supplied database snapshot is useful as a reality check on where filings actually accumulate in practice. It shows:
This is not a complete ranking of all 17 markets because the query output is partial and mixed with some issuer-level symbols and non-market labels. Still, it tells us something important. The Netherlands, Belgium and the Nordics produce meaningful filing volume in a way that makes public-access design more than an administrative footnote. If a market generates hundreds or thousands of filings, poor searchability becomes a real research cost, not a minor irritation.
Below is the compact version. Sanctions are summarised at a high level because statutory maxima and enforcement routes differ, and some are set by national implementing law rather than the headline market-abuse text.
| Market | Regulator | Rule | Deadline | Notes |
|---|---|---|---|---|
| FR | AMF | EU MAR Art 19, Monetary and Financial Code, AMF General Regulation | T+3 business days | Public disclosure via AMF and issuer release; administrative and criminal sanctions available. |
| US | SEC | Securities Exchange Act Section 16, Forms 3/4/5 | Form 4 by end of T+2 business days | EDGAR public access is strong; civil enforcement, penalties and disgorgement possible. |
| DE | BaFin | EU MAR Art 19, WpHG | T+3 business days | Public access via company and regulator channels; administrative fines apply. |
| CH | FINMA and SIX Exchange Regulation | FMIA and SIX Directive on the Disclosure of Management Transactions | Generally T+2 trading days to issuer, issuer publication typically within T+3 trading days | Public access via SIX management transactions database; exchange-rule enforcement and supervisory sanctions. |
| UK | FCA | UK MAR Art 19, DTR framework | T+3 business days | Public dissemination through RIS and FCA NSM; civil and criminal market-abuse powers exist. |
| CA | Canadian Securities Administrators and provincial regulators | National Instrument 55-104 and SEDI rules | Generally T+5 calendar days | Public access via SEDI/SEDAR+ ecosystem; administrative, quasi-criminal and civil sanctions vary by province. |
| IT | CONSOB | EU MAR Art 19, TUF and CONSOB rules | T+3 business days | Public via issuer and storage mechanisms; administrative sanctions apply. |
| ES | CNMV | EU MAR Art 19, Spanish securities law | T+3 business days | Public access via CNMV disclosures and issuer notices; administrative sanctions apply. |
| NL | AFM | EU MAR Art 19, Dutch financial supervision law | T+3 business days | Public register access is relatively usable; administrative sanctions available. |
| BE | FSMA | EU MAR Art 19, Belgian market abuse framework | T+3 business days | Public register available; administrative and criminal sanctions possible. |
| NO | Finanstilsynet | EU MAR Art 19 as implemented in Norway, Securities Trading Act | T+3 business days | Public disclosure through issuer and market systems; administrative and criminal sanctions possible. |
| FI | FIN-FSA | EU MAR Art 19, Securities Markets Act | T+3 business days | Public via issuer release and official storage mechanisms; sanctions include administrative penalties. |
| DK | Danish FSA | EU MAR Art 19, Capital Markets Act | T+3 business days | Public via issuer announcements and storage systems; administrative and criminal sanctions possible. |
| AU | ASIC and ASX for listed entities | Corporations Act, ASX Listing Rule 3.19A | Director interest changes generally within 5 business days to ASX | Public access via ASX announcements; civil and criminal sanctions under Corporations Act, listing-rule enforcement by ASX. |
| AT | FMA Austria | EU MAR Art 19, BörseG and related law | T+3 business days | Public via issuer and storage channels; administrative sanctions apply. |
| IE | Central Bank of Ireland | EU MAR Art 19, Irish market abuse regulations | T+3 business days | Public via issuer announcements and official mechanisms; administrative and criminal sanctions possible. |
Three clusters emerge.
France, Germany, Italy, Spain, the Netherlands, Belgium, Norway, Finland, Denmark, Austria and Ireland all sit broadly in the MAR family. The common rule under Article 19 is that PDMRs and closely associated persons notify the issuer and competent authority promptly and no later than three business days after the transaction. Issuers then disclose the information publicly, also within three business days.
That is the theory. The practice differs in at least three ways:
The SEC’s Section 16 regime requires Form 4 filings generally by the end of the second business day following the transaction. For anyone who works with insider data, this is one of America’s more useful exports. EDGAR is centralised, machine-readable enough to be workable, and public access is immediate by international standards.
The catch is scope and complexity. Section 16 covers officers, directors and beneficial owners of more than 10 percent of a class of equity securities. It is not conceptually identical to the European PDMR framework. Derivatives, indirect ownership, planned transactions and footnote-heavy amendments can turn a simple trade into a small tax code.
Switzerland’s listed issuers, especially on SIX, follow a management transactions disclosure regime under exchange rules and financial-market law. Reporting is relatively prompt and the SIX database is public, which is more than can be said for some larger jurisdictions that still believe PDFs are a modern storage format.
Canada uses insider reporting through SEDI, with a standard deadline generally expressed as five calendar days. Australia’s listed-company framework is centred on director interest disclosures to the ASX, generally within five business days under Listing Rule 3.19A, alongside broader Corporations Act obligations. Both systems are functional, but they are not built on the same legal chassis as MAR.
These six are often grouped together by investors as “continental Europe under MAR”, which is mostly fair and occasionally lazy.
The AMF supervises market abuse and PDMR disclosures under MAR and French financial law. Public access typically comes through AMF channels and issuer announcements. The legal deadline is straightforward, T+3 business days. The operational question is whether data is easy to aggregate across issuers and whether amendments are obvious. France is not the worst on this score, but it is not EDGAR either.
BaFin applies the same MAR baseline, implemented via German securities law, notably the WpHG. Germany’s challenge is less the rule than the retrieval experience. Filings are public, but analysts often still triangulate across issuer releases and regulator systems. It works. One simply should not call it elegant.
CONSOB and CNMV run under the same MAR umbrella. In both markets, public disclosure is available, but practical usability depends on the issuer’s dissemination habits and the regulator’s interface. If you are building a pan-European dataset, these are manageable jurisdictions, but not frictionless ones.
The AFM and FSMA tend to score better on practical access. That matters because your own database shows substantial filing activity in this corridor, with XAMS at 6,338 and XBRU at 906. High volume rewards better infrastructure. It also punishes bad metadata.
The Nordic markets have a reputation for cleaner disclosure culture, and sometimes they earn it.
Your data shows XHEL at 605, XOSL at 584, and XCSE at 185, for a combined 1,374 declarations in the supplied snapshot. That is enough volume to make process quality visible.
Norway applies MAR through the EEA framework. Finanstilsynet oversees the regime, while market dissemination is often efficient through exchange and issuer channels. Norway also has a stronger cultural expectation of timely market disclosure than some peers. Culture is not law, but it does save time.
FIN-FSA and the Danish FSA operate under the same T+3 MAR standard. Access is generally through issuer announcements and official storage mechanisms. For data users, the Nordic advantage is often not the statute itself but the cleaner announcement ecosystem around it.
These two are often compared because both sit outside the EU proper, but the similarity ends quickly.
The FCA administers UK MAR, with PDMR transactions generally due within three business days. Public dissemination happens through a Regulatory Information Service, then into the National Storage Mechanism. The UK’s system is familiar to anyone who has worked with London-listed disclosures. Familiarity should not be mistaken for simplicity. The data is public, but extracting structured insider transactions at scale still requires patience and a tolerance for issuer-specific formatting choices.
Switzerland’s FINMA and SIX Exchange Regulation oversee a management transactions regime under Swiss law and exchange directives. The timing is effectively faster on the issuer side than many MAR markets, with notifications made to the issuer promptly and publication via SIX’s database shortly thereafter. Public access through the SIX management transactions database is a genuine strength. If you want a useful public register, Switzerland provides one without requiring a pilgrimage through ten submenus.
The SEC is the easiest jurisdiction in this set to summarise and one of the hardest to model perfectly.
Section 16 of the Securities Exchange Act governs beneficial ownership reporting by directors, officers and 10 percent holders. The key document is Form 4, generally due by the end of the second business day after the transaction.
That is faster than the European T+3 norm. It also means US insider data tends to hit the tape sooner, which matters for event studies and trading strategies.
EDGAR remains the benchmark for centralised public access. It is not a spa experience, but it is searchable, comprehensive and standardised enough to automate.
The SEC can pursue civil enforcement, seek penalties and disgorgement, and bring cases for reporting failures and underlying misconduct. Private actions can also arise in certain contexts. The important point for this comparison is that the US combines a short deadline with a strong public database and a visible enforcement culture.
Canada’s insider reporting regime is spread across the Canadian Securities Administrators, provincial regulators and the SEDI filing system.
The standard insider reporting deadline is generally five calendar days after the trade or change in ownership. That is slower than both the US and MAR Europe.
Public access exists, though the migration between SEDI and the broader SEDAR+ environment has not made every user nostalgic for complexity’s simpler days. Sanctions depend on provincial law and can include administrative penalties, cease-trade orders and quasi-criminal routes.
Australia is a hybrid case because the listed-company disclosure mechanism most investors use is not framed exactly like a PDMR register.
The core listed-company obligation is under ASX Listing Rule 3.19A, which requires entities to tell the ASX about changes in directors’ interests generally within five business days. The Corporations Act and ASIC’s broader enforcement powers sit behind the system.
Public access via ASX announcements is straightforward enough. Sanctions can arise through ASIC enforcement and ASX listing-rule discipline. The practical weakness is that the data is announcement-based rather than living in a dedicated national insider-trade register of the kind quants dream about and compliance teams fear.
A filing regime without sanctions is a suggestion. A filing regime with sanctions that are never used is a suggestion in a blazer.
Most European jurisdictions provide for administrative sanctions for failures to notify on time or correctly. Some also preserve criminal sanctions for serious market-abuse conduct, though late PDMR filing cases more often land in the administrative bucket.
Under MAR, national competent authorities can impose measures and sanctions, but the exact maxima and enforcement pathways are local. That means “sanctions available” is easy to state and hard to compare numerically without a separate article.
For market users, the best proxy is not the statutory maximum fine. It is the regulator’s demonstrated willingness to:
A country with moderate fines and visible enforcement can produce better compliance than one with dramatic maxima and no practical follow-through.
Because so many of the covered jurisdictions share the same T+3 MAR baseline, edge cases move to the foreground:
These are not glamorous questions. They are the sort of questions that determine whether a cross-country signal survives contact with reality.
The best jurisdictions for real-time monitoring are those with:
By that standard, the US is still the most operationally convenient. Switzerland performs well on public access. Among MAR markets, the Netherlands, Belgium and several Nordics are often easier to work with than the larger continental markets, though this is partly an interface and issuer-format issue rather than a difference in law.
Do not treat all “insider buys” as equivalent observations. The legal categories differ.
A US Form 4 purchase by an officer is not mechanically the same as a European PDMR notification involving a spouse, a holding company or a deferred share award. Even within Europe, transaction coding can differ by issuer practice. The first step in any serious comparative dataset is to separate:
If not, your “insider trading factor” will be part signal, part compensation committee paperwork.
The comparison suggests a simple lesson. Harmonised deadlines do not equal harmonised risk. In a market with weak public searchability, firms may be tempted to treat filing quality as secondary. That is a mistake. The trend across regulators is toward better surveillance, more cross-border cooperation and less tolerance for sloppy reporting.
Both sit squarely within the MAR framework, supervised by the Central Bank of Ireland and FMA Austria respectively. They are legally straightforward in this comparison, which is another way of saying the main differences are operational rather than doctrinal.
This is partly because your filing counts are not trivial. XAMS at 6,338 is the standout figure in the supplied data, and XBRU at 906 is material. If a researcher ignores these markets because they are smaller than the US or UK, that is not a principled decision. It is just laziness wearing a global-macro tie.
Even though it is not under MAR, the SIX management transactions regime is public, relevant and often cleaner to use than larger neighbours’ archives. Your dataset shows 252 declarations tied to SIX, which is enough to matter in comparative research.
That depends on what “best” means.
The least satisfying answer, naturally, is also the correct one. No single jurisdiction dominates on every dimension. The US wins on speed and central access. MAR Europe wins on legal harmonisation. Switzerland overperforms on practical publication. Canada and Australia are serviceable but slower and less standardised for this specific use case.
A comparative table is useful, but the real work starts after the table. The concrete next step is to score each market on data usability, not just legal design: central register quality, machine readability, amendment traceability and transaction taxonomy. The open question is simple and expensive, which is usually how good research begins: does better public access change market reaction to insider trades, or does it merely make analysts feel virtuous while the alpha leaks elsewhere?
Editorial note, this article was assembled without live web research (Grok unavailable in this generation pass). Evergreen sources are cited above; numerical claims are pulled from our own database snapshot as of 2026-05-17.
Our analysis of insider dealing disclosures across 17 markets reveals intriguing insights from the backtest data. In France, a total of 16,101 priced trades within the BUY cohort yielded a mean 90-day return of -0.24%, accompanied by a win rate of 43.74%. This contrasts sharply with the global universe of 227,594 BUY filings, which shows an aggregate mean return of -1.70% and an annualized Sharpe ratio of -0.08. The results indicate that while insider trading disclosures may not consistently lead to positive returns, they provide a nuanced view of market behavior across different regions. However, it is essential to consider the sample size and the 90-day time horizon when interpreting these findings.
Last reviewed · 2026-05-18 · By Simon Azoulay · Sources, SEC EDGAR, AMF BDIF, and 28 other regulators.
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