Insider Trading & Regulation
MAR Article 19 (PDMR dealings)
The EU Market Abuse Regulation rule requiring persons discharging managerial responsibilities, and people closely associated with them, to disclose their trades within three business days.
Article 19 of Regulation (EU) No 596/2014 is the European counterpart to the SEC's Section 16. It obliges a PDMR (a director or senior executive with access to inside information) and any closely associated person (spouse, dependent children, controlled entities) to notify both the issuer and the national competent authority of every transaction in the issuer's financial instruments.
- Threshold: notification is required once aggregate transactions in a calendar year exceed EUR 5,000 (a member state may raise it to EUR 20,000).
- Deadline: three business days after the transaction date, versus the SEC's two.
- Closed periods: a PDMR may not trade during the 30 calendar days before an interim or year-end financial report.