CH-Listed Companies

Rules written by SIX

Switzerland is outside the EU Market Abuse Regulation. Dealings by company leaders are governed by the exchange itself: article 56 of the SIX Listing Rules and the Directive on the Disclosure of Management Transactions (DMT), last revised with effect from 1 February 2024. The duty applies to issuers whose equity securities have their primary listing on SIX Swiss Exchange, and it falls on members of the board of directors and of the executive committee.

Reportable instruments are the shares, conversion, purchase or sale rights on them, and cash-settled instruments linked to them. Trades by related parties count when made under the significant influence of a board or committee member, such as a company the member controls. Allocations under an employment contract or a compensation plan are exempt when the member cannot trigger them by a conscious decision, but a later exercise or sale must be reported. The DMT sets no minimum value, and purchases and sales made on the same day may not be netted.

Two deadlines, counted in trading days

The member must notify the company no later than the second trading day after the transaction. The company then has three further trading days to forward the notice to SIX Exchange Regulation (SER) through its electronic reporting platform, and publication follows. The SER guideline gives the example of a trade on a Thursday, a notice to the company the following Monday and a filing on the Thursday after, one week later.

Function shown, name withheld

SER publishes the capacity of the person (executive or non-executive board member, or member of the executive committee), the type of transaction, the instrument and its ISIN, the quantity, the total value in Swiss francs and the trade date. The name and date of birth are collected but not published. Entries stay searchable on the SER website for three years. The company's own buybacks fall outside the regime.

Insider pages for Swiss companies on this site therefore show a role in place of a name. The feed is per-trade, amounts are reported in CHF and converted to euros, and history starts in January 2023. The methodology explains how roles and amounts are normalised.

Stakes above 3%: a separate track

Shareholding disclosure is a different obligation, set by article 120 of the Financial Market Infrastructure Act (FinMIA): anyone whose voting rights reach, exceed or fall below 3, 5, 10, 15, 20, 25, 33⅓, 50 or 66⅔% must notify the company and the exchange. FINMA enforces it. Those filings are not part of the management-transactions feed shown here.