Key dates
- December 4, 2024
- EU Regulation 2024/2809 enters into force; , amending MAR on inside information and disclosures
- June 5, 2026
- Certain amendments to insider trading policies apply; (e.g., in Groupe Casino policy)
- June 30, 2026
- AMF General Regulation updates take effect; , covering prospectuses and admissions
- Within 3 trading days Deadline
- PDMRs must report transactions; to issuer and AMF
Suggested considerations
- Enhance insider lists and training: Maintain updated lists of permanent/occasional insiders; train on MAR Article 7/17 prohibitions, including risks of "insider networks" linked to organized crime.
- Implement/enforce black-out periods: Prohibit trading 30 days before annual/interim results and 15 days before quarterly info for executives and insiders; notify via Insider Trading Committee.
- Strengthen policies on gifts/invitations and whistleblowing: Formalize in codes of ethics; monitor for corruption risks in information sharing.
- Monitor and report transactions: PDMRs and related persons report within 3 days; firms oversee compliance function role in breaches.
- Conduct risk assessments: For consolidation teams' access to inside info; integrate AMF/AFA joint vigilance calls.
What changed
This is an enforcement decision, not a regulatory change, but it aligns with ongoing Market Abuse Regulation (MAR) requirements under EU rules transposed in France, including Article 17 prohibitions on insider dealing. No new requirements are introduced; it exemplifies application of existing rules like black-out periods (30 days before annual/interim results, 15 days for quarterly) and trading bans for insiders, as recommended by AMF Position-Recommendation No 2016-08.
Compliance impact
Urgency: High – This demonstrates AMF's focus on executive accountability in insider dealing, amid rising "insider networks" concerns noted in 2024/2025 reports, with joint AMF/AFA warnings amplifying detection risks. Firms face fines, reputational damage, and procedural enhancements under strengthened AMF powers (e.g., 2025 Labaronne bill), making immediate policy reviews essential for listed entities.