#32026R1291EU updates the standard format for insider lists under market abuse rules
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This regulation updates the templates that listed issuers and other market participants must use to keep insider lists. These lists record people who have access to inside information, such as employees, advisers, accountants, credit rating agencies, and others working for or with the company. The practical change is about consistency and enforcement. Companies subject to EU market abuse rules must use the new format when creating and updating insider lists, including special formats for SME growth market issuers. Compliance teams should review their internal insider-list processes and replace older templates based on Regulation 2022/1210.
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Key Changes
- Sets updated standard templates for insider lists under the EU Market Abuse Regulation
- Covers issuers, emission allowance market participants, auction platforms, auctioneers, auction monitors, and people acting for them
- Repeals the previous implementing regulation on insider-list formats, Regulation 2022/1210
Obligations
What this law requires
Draw up and promptly update an insider list of all persons who have access to inside information and who work for the entity under an employment contract or otherwise perform tasks giving them access to inside information, including advisers, accountants and credit rating agencies.
Maintain insider lists in the precise format and standard templates laid down by Commission Implementing Regulation (EU) 2026/1291, replacing formats based on Commission Implementing Regulation (EU) 2022/1210.
Ensure insider lists contain the information necessary for competent authorities to investigate possible market abuse and protect financial market integrity, using the required insider-list format.
Issuers whose financial instruments are admitted to trading on an SME growth market may maintain the SME-growth-market insider-list format for persons who have regular access to inside information due to the nature of their function or position, where applicable under Article 18 of Regulation (EU) No 596/2014.