Topic Information obligations for issuers Issuers
Article from Issuer Guidelines published by the Federal Financial Supervisory Authority
Under Article 18(7) of the MAR, the obligation to draw up an insider list applies to all issuers who have applied for or approved admission of their financial instruments to trading on a regulated market in a member state or, in the case of instruments only traded on a multilateral (MTF) or organised trading system (OTF), issuers who have had their financial instruments approved for trading on a multilateral or organised trading facility in a member state or have applied for admission to trading of their financial instruments on a multilateral trading facility in a member state. Supplementing the previous rules, this means that Freiverkehr (regulated unofficial market) issuers in particular are required to draw up insider lists.
For guidance on what is understood to be a multilateral or organised trading facility, and when the issuer has approved trading there, see section I.3.2.1.1, third and fourth paragraphs.
