The Market Abuse Regulation (MAR) has direct effect as law in the United Kingdom from 3 July 2016. Broadly, it replaces the current regime in relation to the disclosure of and delaying the disclosure of inside information, insider lists, dealings and related notifications by persons discharging managerial responsibility (PDMRs), as well as establishing procedures for market soundings. The key issues and actions for issuers are summarised below.
What is changing for issuers?
While broadly the rules relating to inside information are not changing, the related record-keeping requirements under MAR are more onerous than under the existing regime. Under MAR, the scope and nature of disclosure of dealings by PDMRs is changing, including in relation to processes and timing for notifications as well as in relation to closed periods. MAR also introduces a new safe harbour for the disclosure of inside information in certain market soundings so long as its procedures and record-keeping requirements are satisfied.
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