GUIDE
Insider dealing disclosure rules in Europe
The EU, Norway, the UK and Switzerland all require company managers to disclose trades in their own company's shares, with different deadlines, thresholds and published details. This page sets the 14 markets side by side, with the time disclosure actually took.
The EU rules (MAR Article 19)
- Who files: persons discharging managerial responsibilities (PDMRs) and persons closely associated with them, under Article 19 of the EU Market Abuse Regulation (MAR).
- Deadline: the person notifies the company and the regulator within 3 business days of the trade; the company makes it public within 2 business days of receiving it. Up to about 5 business days from trade to publication.
- Threshold: under EU rules EUR 20,000 in a calendar year since 4 December 2024 (EUR 5,000 before); a national regulator may set it anywhere from EUR 10,000 to EUR 50,000.
- Closed period: the 30 calendar days before a year-end or interim report, unless the company grants a permitted exception.
The UK and Switzerland differ; see their pages.
The 14 markets
| Market | Rules | Purchase filings | Median business days | Over 5 business days |
|---|---|---|---|---|
| Germany | MAR | 2,871 | 1 | 3% |
| Sweden | MAR | 13,317 | 1 | 2% |
| Norway | MAR (EEA) | 1,257 | 0 | 0% |
| Italy | MAR | 117 | 1 | 3% |
| France | MAR | 5,731 | 2 | 7% |
| Finland | MAR | 952 | 1 | 1% |
| Denmark | MAR | 217 | 1 | 1% |
| The Netherlands | MAR | 1,350 | — | — |
| The United Kingdom | UK MAR | 8,678 | 0 | 1% |
| Belgium | MAR | 1,553 | 2 | 15% |
| Switzerland | SIX | 2,156 | — | — |
| Spain | MAR | 1,695 | 2 | 7% |
| Austria | MAR | 40 | 1 | 5% |
| Poland | MAR | 259 | 1 | 3% |
Dates are the ones stated in the filing. Where a filing gave no separate trade date, most sources repeat the publication date, so same-day figures are overstated and the share that took longer is a lower bound. Gaps under zero or over 250 business days are treated as date errors and left out. A late filing can have an ordinary cause, such as a correction of an earlier notice.