NL-Listed Companies
Regulator: AFM.
Insider notifications in the Netherlands: two AFM registers, one now closed
Two registers that look alike
The Dutch Authority for the Financial Markets (AFM) has run two public notification registers for insiders. The managers' transactions register (MAR 19) lists dealings by managers in the issuer's shares, debt instruments or linked derivatives: purchases, sales, the receipt of employee options. You can search it by date, issuer and notifying person, and export it as CSV or XML.
The second register covers directors and supervisory board members (bestuurders en commissarissen). It records holdings: the shares and votes each board member holds in a Dutch public limited company (NV) listed on an EU regulated market, and every change in them.
What article 5:48 Wft required
Article 5:48 of the Financial Supervision Act (Wft) obliged every director and supervisory board member to report their shares and votes in the issuer, and in affiliated issuers, within two weeks of appointment, then to report each change without delay. The article set no amount threshold, so it caught small changes that MAR article 19 leaves out.
Repealed on 29 September 2026
The Dutch law implementing the Listing Act (Implementatiewet noteringen en benchmarks, Act of 8 July 2026, Bulletin of Acts 2026, 216) deleted the Wft section that contained article 5:48, with effect from 29 September 2026. Dutch board members now report under MAR article 19 alone, from the EU default of 20,000 euros a year; the Netherlands is not on ESMA's list of regulators that changed it.
Substantial holdings are a separate regime that stays in place: under article 5:38 Wft, anyone reaching or crossing 3%, 5%, 10% and higher steps up to 95% of capital or votes notifies the AFM.
Reading the Dutch data here
The Netherlands hub combines both registers. A row from the board register describes a change in holdings. That register does not say whether the change was a purchase or a sale, so we infer the direction from the positions before and after, and leave it unclassified when those positions are incomplete. Expect no new rows of that kind after September 2026. Rows from the MAR 19 register are individual transactions.