Topic MVP-Portal Ad hoc disclosure – Notification under section 26 (1) of the German Securities Trading Act (Wertpapierhandelsgesetz – WpHG)
Under section 26 (1) of the WpHG, a domestic issuer, an MTF issuer or an OTF issuer that is required by Article 17(1), (7) or (8) of MAR to make public inside information must provide it to BaFin (“notification”). If a domestic issuer, an MTF issuer or an OTF issuer delayed disclosure under Article 17(4) of MAR, under Article 6 of Commission Delegated Regulation (EU) 2016/522 it must inform BaFin that disclosure of the information was delayed and provide a written explanation of how the conditions for a delay were met, immediately after the information is disclosed to the public (“delay notification”).
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It is important to be aware that the publication of an ad hoc disclosure and the Europe-wide dissemination of this disclosure is independent of the notification under section 26 (1) of the WpHG. The disclosure is deemed to have been disseminated Europe-wide when it is published via one of the providers that offer this service. These service providers will usually also take care of notifications under section 26 (1) of the WpHG.
Electronic transmission of advance notifications
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From 02th July 2025, notifications can also be submitted to BaFin in electronic form. If it was decided prior to the disclosure that the disclosure was to be delayed under Article 17(4) of MAR, the delay notification can also be transmitted electronically together with the notification. This also applies to updates and corrections under section 4 (2) and (3) of the German Securities Trading Reporting Regulation (Wertpapierhandelsanzeigeverordnung – WpAV). BaFin's reporting and publishing platform, the MVP Portal, is to be used for the electronic submission of notifications and delay notifications to BaFin.
To transmit notifications electronically, the issuer can use an online form in the specialised procedure (“Ad hoc disclosure”) that provides guidance on completing a number of the fields (for more information, please refer to the information sheet on using the specialised procedure “Ad hoc disclosure “ under “Additional information”)
Once you have registered on the MVP Portal, you can apply for access to the specialised procedure “Ad hoc disclosure” (for more information, please refer to the information sheet regarding registration for and access to the specialised procedure “Ad hoc disclosure “ under “Documents relating to the specialised procedure”). After you have submitted the application for access by fax (or post) to BaFin, the relevant BaFin division will promptly grant you access to the specialised procedure. Please note that this can take several working days. If you need to submit an notification in the period between submitting your application and your account being activated, please continue to use the following fax number: +49 (0)228/4108-200.
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A test version of the specialised procedure “Ad hoc disclosure” is available for you to use. When the test version of the procedure is used, electronic notifications are not submitted in a manner that is legally valid. Further information about the test version of the procedure can be found on the page for the specialised procedure "TEST Ad hoc disclosure”. In order to use the specialised procedure "TEST Ad hoc disclosure”, you will need to be granted access specifically for this procedure. This access cannot be used for the legally valid transmission of electronic notifications in the specialised procedure “Ad hoc disclosure”.
Further information on the legal basis for the disclosure of inside information under Article 17 of MAR and on the form and content of notifications and delay notifications can be found in the Issuer Guidelines - Module C, Requirements based on the Market Abuse Regulation (see: Issuer Guidelines - Module C).
Please address any technical questions you have regarding the electronic specialised procedure “Ad hoc disclosure” to: p26_1wphg@bafin.de.
If you have any technical questions or problems relating to registration and the use of the MVP Portal, please contact technical support: mvp-support@bafin.de.
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Please note that electronic notifications can only be submitted after your access to the specialised procedure “Ad hoc disclosure” has been activated. We will use the details you provide during registration to inform you by e-mail when you have been granted access to the specialised procedure.
