ESMA_QA_777
19/04/2023
Subject Matter
Information to be included into insider list of the issuer on persons that are subject to independent obligation to manage insider list (e.g. advisors and consultants)
    As certain persons have an independent obligations to draw up and manage insider list of the issuer (e.g. advisors, consultants, credit agency) under Article 18(1) of MAR, what information should be reflected in the insider list of the issuer: (i) all required information under insider list template for a contact person of such third party, in addition in the field "function and reason for being insider" indicating that this is only a contact person of third party that has independent obligation to draw-up and manage independent insider list, or (ii) with deviation from template of insider list, name and contact details of such company itself, omitting certain fields, such as name, surname, birth surname.
    Status: Forwarded to EC/Public Consultation/Other

    Additional Information

    Level 1 Regulation
    Market Abuse Regulation (MAR) Regulation (EU) No 596/2014 - Market Intergrity
    Level 2 Regulation
    Regulation 2016/347- ITS on format of insider lists
    Additional Legal Reference
    Article 18(1) of MAR
    Topic
    Insider lists