The Commission Implementing Regulation (EU) 2026/1291 (the “Implementing Regulation“) entered into force on 5 July 2026, introducing a revised set of implementing technical standards on insider list formats and repealing Implementing Regulation (EU) 2022/1210.
The amendments, introduced as part of the Listing Act’s objective of reducing administrative burdens, remove a number of personal data fields and extend the alleviated insider list format (previously available only to SME growth market issuers) to all issuers required to maintain insider lists under the Market Abuse Regulation (“MAR“).
Background
An insider list is a record that issuers and any legal person acting on their behalf or on their account are required to draw up and maintain of all individuals who have access to inside information, whether under a contract of employment or through otherwise performing tasks that give rise to such access, such as advisers, accountants, or credit rating agencies.
For the purposes of MAR, inside information is information of a precise nature which has not been made public, which relates directly or indirectly to one or more issuers or financial instruments, and which, if it were made public, would be likely to have a significant effect on the prices of those financial instruments or related derivatives.
Key clarifications
The Implementing Regulation introduces a number of clarifications, including the following:
- Where a legal person acts on behalf of, or on the account of, an entity (third-party service provider) and has access to inside information, issuers must now include details of only one natural person acting as a contact person per third-party service provider on their insider list;
- Persons who, due to the nature of their function or position within the issuer, have access to inside information at all times, may continue to be listed in a separate permanent section of the insider list (Permanent Insider List). Such permanent insiders should not simultaneously be included within the Temporary Insider List;
- Issuers must delete the personal data relating to persons included on their insider lists five years after such persons ceased to be on an insider list.
Simplified Templates
The following amendments have been made to the personal data fields applicable to both the Temporary Insider List and the Permanent Insider List:
- The following fields have been removed: surname(s) at birth (if different); company name and address; personal telephone number; and personal full home address;
- The insider’s National Identification Number must be included, and only where this is not applicable, the insider’s date of birth; it is no longer required to include both;
- The ‘Function and reason for being insider’ field must now include, where the insider is a third-party service provider, the name and address of the relevant company.
With respect to the Permanent Insider List specifically, the “Included” field has been replaced by the “Obtained” field and a new “Ceased” field has been introduced. Accordingly, permanent insiders should no longer be removed from the Permanent Insider List once they cease to have access to all inside information at all times. Instead, the date on which such access ceased should be recorded.
Next steps
Issuers should review and update their existing insider list templates without delay to reflect the new requirements introduced by the Implementing Regulation and ensure that all future insider lists are prepared in accordance with the revised formats.
While the amendments reduce certain administrative requirements, they do not alter the core obligations under the Market Abuse Regulation. Issuers must continue to draw up, maintain and promptly update insider lists whenever inside information exists.
Should you require further guidance on the revised insider list formats or advice on any other aspect of compliance with the Market Abuse Regulation, please do not hesitate to contact us.
