MAR Article 19 in practice: deadlines, thresholds and closed periods

Who must notify under Article 19

The Market Abuse Regulation (596/2014) defines the reporting population in Article 3, and Article 19 attaches the obligation to it. Two groups are covered.

Persons discharging managerial responsibilities (PDMRs), per Article 3(1)(25), are members of the issuer's administrative, management or supervisory body, plus senior executives who sit on none of those bodies but have both regular access to inside information relating directly or indirectly to the entity and the power to take managerial decisions affecting its future development and business prospects. A head of M&A can be a PDMR without a board seat. A well-paid engineer with inside information but no decision power is not.

Closely associated persons, per Article 3(1)(26): a spouse or a partner treated as equivalent under national law, a dependent child, a relative who has shared the household for at least one year at the transaction date, and any legal person, trust or partnership whose managerial responsibilities are discharged by a PDMR (or one of the previous three), or which is directly or indirectly controlled by, set up for the benefit of, or economically equivalent to such a person. The family holding company files just like the CEO does.

The regime applies to issuers that requested or approved admission of their instruments to a regulated market, or that approved trading (or requested admission) on an MTF or OTF (Article 19(4)). Article 19(10) extends the same mechanics to emission allowance market participants.

What transactions get reported

Article 19(1) is broad by design: every transaction conducted on the PDMR's own account in shares or debt instruments of the issuer, or in derivatives or other financial instruments linked to them. Article 19(7) then spells out cases people would otherwise argue about: pledging or lending of financial instruments, transactions executed by professional arrangers or under discretionary mandates (even without the PDMR's instruction), and transactions under life insurance policies where the PDMR bears the investment risk and has the power to make investment decisions. One carve-out: a pledge sitting in a custody account is not notifiable unless and until it is designated to secure a specific credit facility.

Delegated Regulation (EU) 2016/522, Article 10(2), turns that principle into a long concrete list. The entries that surprise people:

One genuine exception exists. Under Article 19(1a), no notification is required for transactions in units of a fund or portfolio where exposure to the issuer's securities does not exceed 20 percent of the assets, provided the PDMR does not know, and could not know, the composition. Buying a broad index fund does not trigger a filing.

The threshold: EUR 20,000 per year since December 2024

Between 2016 and 2024, the notification duty kicked in once transactions reached EUR 5,000 within a calendar year, aggregated without netting (Article 19(8)), and national competent authorities could raise that to EUR 20,000 (Article 19(9)).

The EU Listing Act (Regulation (EU) 2024/2809 of 23 October 2024, applying from 4 December 2024) rewrote both numbers. The baseline is now EUR 20,000 per calendar year, and the amended Article 19(9) lets each NCA either raise the trigger to EUR 50,000 or lower it to EUR 10,000, informing ESMA of its choice. The result is a threshold map, not a threshold:

The practical consequence: a EUR 30,000 purchase by a French director is no longer notifiable at all, while the same trade in Malta is. Comparing filing counts across EU markets after December 2024 without adjusting for this is a methodological error.

The three business day clock

Article 19(1) requires the PDMR or closely associated person to notify both the issuer and the national competent authority "promptly and no later than three business days after the date" of the transaction.

Publication is a second, separate clock. Originally the issuer also had three business days from the transaction, which was arithmetically impossible whenever the PDMR used the full three days. Regulation (EU) 2019/2115 (27 November 2019) fixed this: the issuer must make the information public within two business days of receipt of the notification, and that amendment applies from 1 January 2021. Worst case, a trade becomes public five business days after execution. Compare the US, where Form 4 hits EDGAR within two business days of the trade itself.

Where notifications are published

Nowhere central, and that is the defining weakness of the regime. Article 19(3) requires the issuer to publish the notification "in a manner which enables fast access" on a non-discriminatory basis; national law may instead put publication in the hands of the NCA, which is what France does through the AMF. So the same legal act surfaces as a BDIF record in Paris, a database row at BaFin in Bonn, a stock-exchange notice elsewhere.

This will eventually change. Regulation (EU) 2023/2859 creates the European Single Access Point (ESAP), and ESMA must make it available by 10 July 2027, with datasets phased in over the following years. Until MAR data actually flows into ESAP, anyone who wants a pan-European view has to collect it country by country.

How to read an Article 19 notification

Commission Implementing Regulation (EU) 2016/523 fixes the template every EU notification follows, whatever language it is filed in. The Annex fields:

Field 2 deserves a habit: an "amendment" notification corrects an earlier one and should replace it in any dataset, not add to it. Field 4b carries the signal; a purchase and a pledge look identical in volume terms and mean entirely different things.

Interpretation traps

Closed periods shape the calendar

Article 19(11) bars a PDMR from trading, on own account or for a third party, during the 30 calendar days before the announcement of an interim or year-end financial report. Article 19(12) allows exceptions (severe financial difficulty, employee share schemes), and the Listing Act expanded them in 2024: employee schemes covering non-share instruments, and transactions where no active investment decision is made (irrevocable arrangements set up before the closed period, discretionary management, corporate actions, inheritances and gifts, exercise of derivatives on pre-agreed terms). Two consequences for readers of the data: insider activity clusters right after results, by construction; and a filing dated inside a closed period is usually an exempt category, not a violation.

Aggregation without netting

The annual threshold counts gross. A EUR 15,000 purchase followed by a EUR 15,000 sale is EUR 30,000 toward the trigger, not zero. And once the threshold is crossed, every subsequent transaction in the calendar year is notifiable, however small.

Zero-price rows are not data errors

Gifts, donations, inheritances and share awards are notifiable under 2016/522 Article 10(2)(k) and show up at zero or nil price. These are non-market transfers, not bugs in the feed, and no buy/sell conviction should be read into them.

One option exercise, two rows

Exercising options at the strike and selling the resulting shares in the market produces two separately notifiable transactions. Counting both as independent trades double-counts one economic decision; reading the exercise row as a purchase at market price misprices it entirely.

A pledge is not a sale

Pledged shares stay owned. A large pledge can hint at personal leverage, which is its own kind of information, but treating it as a disposal corrupts any net-buying metric.

How insiders-trades.com tracks MAR filings

Because no central EU register exists, we ingest each national publication channel separately and normalise the results into one declaration model. For France, that means the AMF BDIF database (IDs like 2026DD1095929), with the PDF notification bodies parsed for role, instrument, price and volume. For Germany, the BaFin directors' dealings database, pulled through its per-letter browse and CSV export and keyed on BaFin-ID. For the UK's retained version of the same regime, the FCA National Storage Mechanism. Consob, CNMV, AFM, FSMA and other national channels feed the same pipeline, with roles normalised across 28 regulators and amounts converted to EUR.

Browse the output on the French market hub or the German market hub, or start from an issuer page such as SAP or TotalEnergies. For the national layer on top of this rulebook, see the AMF insider declarations guide, and for how MAR compares with the US, Canada or Japan, the insider disclosure rules by country index.