The Market Abuse Regulation (MAR) has direct effect as law in the United Kingdom from 3 July 2016. MAR extends the market abuse framework and its disclosure obligations to AIM companies. The key obligations relate to inside information, insider lists, dealing disclosure by persons discharging managerial responsibility (PDMRs) and procedures for market soundings. The key issues and actions for AIM companies are summarised below.
What is changing for AIM companies?
While most AIM companies seek to comply with the provisions of the existing Market Abuse Directive, MAR extends the market abuse framework to require compliance by AIM companies. The detailed record-keeping requirements under MAR in relation to delaying the disclosure of inside information and insider lists require AIM companies to be clear on its definition of inside information as well as have systems and procedures in place to satisfy its record-keeping requirements. Likewise in relation to PDMRs, MAR requires additional record keeping and the amended AIM Rules require a dealing policy. MAR also introduces a new safe harbour for the disclosure of inside information in certain market soundings so long as relevant processes are satisfied.
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