PL-Listed Companies

The supervisor wants the notice on the trade date

On 17 February 2026 the Office of the Polish Financial Supervision Authority (UKNF) published its reading of Article 19 of the Market Abuse Regulation. MAR gives a manager or a closely associated person at most three business days to notify the issuer and the KNF. The UKNF reads "promptly" more strictly: as a norm, the notice should reach the issuer before the end of the trading session on the day of the trade, and the three-day limit is reserved for chance, personal or operational obstacles.

Late or incomplete notices expose the manager to an administrative fine under Article 175 of the Act on Trading in Financial Instruments, and the UKNF says it will use that power firmly.

Threshold and the shape of a notice

The same paper restates the EUR 20,000 yearly threshold, counted by adding every transaction without netting purchases against sales; once it is crossed, each later trade must be reported. ESMA's list of 21 May 2026 shows no Polish decision to raise or lower it. Following Implementing Regulation (EU) 2016/523, a notice lists each transaction of the day and an aggregated line per transaction type with a volume-weighted average price, and purchases and sales are never offset.

From the issuer to ESPI

The issuer then has two business days to publish, a deadline the UKNF calls final; where it can, publication should follow the close of the session on the trade date. Current reports go out through ESPI, the electronic reporting system administered by the KNF, and the Warsaw Stock Exchange lists company ESPI/EBI reports on its own site.

What the Polish rows contain

The Polish feed is classed per-trade, but many rows carry only the header of the notice: issuer, person, role and date. The złoty amounts sit in the PDF attached to the report, and a row stays out of scoring until its amount is extracted. When an amount is read, it is converted to euros and the złoty figure stays visible. The methodology page describes how incomplete rows are handled.