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Guide · Germany · BaFinChecked Oct 31, 2026

When does an insider have to report a trade in Germany?

In Germany the trades of company managers are called directors' dealings or Eigengeschäfte von Führungskräften. The managers report them to BaFin, the federal financial regulator, and the company publishes them.

The rule

Germany applies Article 19 of the Market Abuse Regulation with no national duty on top. BaFin receives the notifications. The MAR guide covers the EU rule in full.

Who has to report

A German stock corporation (AG) has two boards, and both count: the Vorstand (management board) and the Aufsichtsrat (supervisory board). Senior executives with regular access to inside information report as well, and so do their closely associated persons: a spouse or registered partner, dependent children, relatives who shared the household for at least a year, and companies they control.

The €50,000 threshold

BaFin used the room that MAR gives national regulators. By a general decree of 4 December 2025 it raised the threshold to €50,000 per calendar year, from 1 January 2026. Most other EU countries use €20,000 (ESMA list of national thresholds).

BaFin expects up to a third fewer notifications. If you compare German filing counts for 2025 and 2026, part of the drop comes from the new threshold: a manager who bought €30,000 of shares in 2025 had to report it, and in 2026 does not.

The deadline and the publication

The manager notifies the company and BaFin within three business days of the trade. The company then has two business days to publish the notification through media that reach the whole EU, and it sends it to the Unternehmensregister, the German company register. BaFin keeps the notifications in a public database.

German filings on this site

Insider Trades shows the BaFin filings as facts, next to the Dutch, Belgian, Swedish, Spanish and US filings, each row with a link to the source. We do not score German filings; the methodology page explains why the score covers the Dutch register only.

Checked against the regulation and the regulator’s own pages on Oct 31, 2026. This guide explains the rules; it is not legal or investment advice.

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