When does an insider have to report a trade in the Netherlands?
If you sit on the board of a Dutch listed company and you trade its shares, you report that trade to the AFM. Two rules apply: the EU Market Abuse Regulation and the Dutch Financial Supervision Act (Wft).
The rule
Article 19 of the Market Abuse Regulation covers managers of companies whose shares trade on a regulated market such as Euronext Amsterdam. The Dutch Authority for the Financial Markets (AFM) receives their notifications and publishes them in its register of transactions by managers. The MAR guide explains the EU rule itself; this page covers what the Netherlands adds.
Who has to report
- Members of the management board and the supervisory board.
- Senior executives with regular access to inside information and the power to take decisions about the company's future.
- Their closely associated persons: a partner, dependent children, relatives who shared the household for at least a year, and companies they manage or control.
The deadline and the threshold
You notify the AFM and the company within three business days of the trade. The duty starts once your trades in a calendar year add up to €20,000. The trade that takes you past that amount is the first one you report, and each trade after it in the same year follows.
The AFM kept the EU default of €20,000. Germany, France, Italy and Denmark chose €50,000, and Malta €10,000 (ESMA list of national thresholds).
A second Dutch duty for board members
Article 5:48 of the Wft adds a national duty. Members of the management board and the supervisory board of a Dutch listed company report the shares and voting rights they hold in that company to the AFM, and each change in them. This duty has no threshold, so a Dutch director can file twice for one trade: once under MAR and once under the Wft.
How a filing reaches the AFM
You file through the AFM Portal, in the form for Article 19 MAR. A company secretary or an adviser can file for you once you authorise them in the portal; you stay responsible for what the filing says. The AFM plans to accept these notifications only through the portal from the fourth quarter of 2026, and no longer by e-mail.
Dutch filings on this site
Insider Trades lists the AFM filings next to those from Germany, Belgium, Sweden, Spain and the US, with a link to the original notification on every row. The Dutch register is the one we score: the methodology page explains the Insider score and how we calculate it. The count per year and per sector is in the Netherlands in numbers. The AFM register next to the other official registers: how to track insider trades for free.
- Buyer clusters: days on which three or more insiders bought at the same company.
- Buying streaks: one insider buying on consecutive filing days.
- Company index: a page per company, with its filings and share price.
- News: filings that arrived after the three-day deadline, among other items.
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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