Key dates
- December 4, 2024
- EU Regulation 2024/2809 enters force; , amending MAR on inside information and disclosures
- June 5, 2026
- Certain amendments to insider trading policies (e.g., Groupe Casino policy) apply; ; others immediate from February 2025
- June 30, 2026
- AMF General Regulation updates effective; , covering certifications for financial instruments and prospectuses
- Within 3 trading days Deadline
- PDMRs must report securities transactions; to issuer and AMF
Suggested considerations
- Update insider policies: Incorporate AMF-recommended black-out periods (30/15 days), definitions of inside information, and restrictions on index products/derivatives.
- Enhance training and awareness: Train PDMRs, insiders, and staff on MAR prohibitions; formalize in codes of ethics per AMF-AFA joint call (July 9, 2025).
- Strengthen surveillance: Implement transaction monitoring, insider lists (per MAR Article 8), whistleblowing mechanisms, and controls on gifts/invitations.
- Report promptly: PDMRs submit transactions via AMF portal; issuers disclose inside information immediately.
- Conduct audits: Review compliance functions for disciplinary oversight and breach detection, aligning with AMF inspection findings.
What changed
This is an enforcement action, not a regulatory change; it reaffirms existing MAR requirements under Articles 7 (inside information definition), 8 (insider lists), 14 (insider dealing prohibition), 17 (public disclosure), and 19 (PDMR trading restrictions, including 30-day black-out periods before financial results). No new rules are introduced, but it highlights AMF's reliance on firms for detection via internal policies, whistleblowing, and gift/invitation controls, as echoed in recent AMF-AFA guidance.
Compliance impact
Urgency: High – This enforcement signals intensified AMF focus on insider networks, with fines demonstrating willingness to penalize both individuals (€700,000 total) and entities amid a "worrying trend" of organized crime infiltration. Firms face elevated inspection risks, especially post-AMF-AFA vigilance call (2025), and must act preemptively to avoid similar sanctions, as MAR breaches undermine market integrity and investor trust.