BE-Listed Companies
Regulator: FSMA.
Managers' transactions in Belgium: the FSMA's eMT circuit
Notify, confirm, publish
A Belgian manager's trade passes through three hands before you can see it. The manager, or a closely associated person, enters it in eMT, the online application of the Financial Services and Markets Authority (FSMA), which notifies the issuer and the regulator in one step under article 2(3) of Commission Implementing Regulation (EU) 2016/523 and FSMA circular FSMA_2016_08. The issuer then confirms the notification in eMT and forwards it. The FSMA publishes it on its website under article 25, §2 of the Law of 2 August 2002 on the supervision of the financial sector.
A person may mandate someone else to file but stays personally responsible. Several transactions of the same type in the same instrument, on the same day and venue, may go in as one aggregated line or one by one. The FSMA states that the content belongs to the persons who notify.
The EU default threshold, and a wider closed-period exemption
The FSMA applies the Listing Act default. The duty starts once a person's transactions reach 20,000 euros in a calendar year and then covers every later one. The figure rose from 5,000 euros on 4 December 2024, when Regulation (EU) 2024/2809 entered into force. Germany, France and Italy moved to 50,000 euros; Belgium kept 20,000. Notifications are due within three business days of the trade.
The same regulation changed the 30-day closed period before results. Issuers must now allow trades that involve no active investment decision by the manager, result only from external factors or third parties, or follow predetermined terms, such as the exercise of derivatives.
Transparency notifications are a separate stream
Shareholders who cross holding thresholds file transparency notifications, and the company must publish them no later than three trading days after receipt. Those disclose investors' positions. The Belgium hub shows per-trade managers' transactions from the FSMA register, with a link to the FSMA notice when available; the methodology explains the processing.