DE-Listed Companies · BaFin · Insiders Trades

German managers have had to disclose dealings in their own company's shares since 1 July 2002, when section 15a of the Securities Trading Act (WpHG) took effect; lawmakers amended it in 2004. Since 3 July 2016 the duty sits in article 19 of MAR. The English label stuck: German market participants still say Directors' Dealings, while BaFin's official term is Eigengeschäfte von Führungskräften.

Managers and their closely associated persons, including relatives who have shared the household for at least a year and companies they control, notify both the issuer and BaFin within three business days of the trade.

Three places a German notification lives

The issuer publishes the notification within two business days of receiving it, through media that reach investors across the EU. Section 26(2) WpHG then requires it to send the same text to the Unternehmensregister, the federal company register that serves as primary storage, and to tell BaFin it has published. BaFin fills its own Directors' Dealings database from that register, usually one to two working days later, for issuers where BaFin is the competent authority.

BaFin keeps each transaction in its database for 12 months after first publication. Anyone who needs older German filings has to go to the Unternehmensregister.

50,000 euros from 1 January 2026

BaFin used the option the Listing Act opened and raised the threshold from 20,000 to 50,000 euros by a general administrative act of 4 December 2025. It set 1 January 2026 as the start so the calendar-year count would not change mid-year. In its notice to ESMA, BaFin wrote that on 2021 to 2024 data the change removes up to a third of notifications, while the median reported annual totals stayed above 100,000 euros in each of those years.

The ban on insider dealing and the 30-day closed period before interim and annual reports still apply in full. On this site German filings are per-trade, and the markets overview sets Germany beside the other regulators.