A&O Shearman | FinReg | ESMA publishes final draft ITS extending alleviated format of insider lists under MAR
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  • ESMA publishes final draft ITS extending alleviated format of insider lists under MAR

    21 October 2025
    The European Securities and Markets Authority (ESMA) has published its final report on the draft implementing technical standards (ITS) extending the use of the alleviated format of insider lists to all issuers under the amended Market Abuse Regulation (MAR), as mandated by the Listing Act (Regulation (EU) 2024/2809). The draft ITS consolidates the existing five insider list templates into three: two templates for event-based and permanent insider lists applicable to non-SME issuers and SME Growth Market issuers in Member States that have opted out of the simplified regime, and a third template for SME GM issuers under the simplified regime, covering persons with regular access to inside information.

    Following its April consultation, ESMA has made no major changes to the templates. It maintained its view that all issuers should report the national identification number of insiders, and where not applicable, their date of birth. ESMA also added a recital clarifying that issuers may include one contact person per external provider with access to inside information. The draft ITS has been submitted to the European Commission, which has three months to decide whether to adopt them.

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