What is a MAR Article 19 notification?
When a director of a listed European company buys or sells shares in that company, the trade has to be made public. The rule behind it is Article 19 of the EU Market Abuse Regulation: it says who reports, what they report and by when.
The rule
The Market Abuse Regulation (EU) No 596/2014, known as MAR, has applied across the EU since 3 July 2016. Article 19 requires people with managerial responsibility at a listed company to report their own transactions in that company's shares, bonds and related instruments. The report goes to the company and to the national regulator, and it becomes public. Anyone can then see when the people who run a company trade in its shares.
Who has to report
The regulation calls them persons discharging managerial responsibilities, often shortened to PDMR. In practice:
- Members of the management board and the supervisory board (or the board of directors).
- Senior executives who have regular access to inside information and the power to take managerial decisions about the company's future.
- Persons closely associated with them: a spouse or partner, dependent children, relatives who have shared the household for at least a year, and companies or trusts they manage or control.
The deadline and the threshold
The person must notify promptly, and no later than three business days after the transaction. The company publishes the notification as well.
Small trades are exempt until their total passes a threshold. Since the EU Listing Act took effect on 4 December 2024 the threshold is €20,000 per calendar year (it was €5,000 before). National regulators may lower it to €10,000 or raise it to €50,000; Germany's BaFin set it at €50,000 from 1 January 2026. Once a person passes the threshold, they report every further transaction in that year.
Separately, a PDMR may not trade during a closed period of 30 calendar days before the company announces its interim or year-end results, with narrow exceptions.
What a notification contains
- The name of the person, and their position (or the person they are closely associated with).
- The company, with its legal entity identifier (LEI).
- The instrument, usually with its ISIN.
- The nature of the transaction: a purchase, a sale, a grant, an exercise of options, a gift, a pledge.
- The date and the trading venue.
- The price and the volume, and for several trades the aggregated volume and the weighted average price.
How to read one
Many notifications are not trades on the open market. A director also reports shares received under a pay plan, options exercised, and shares given away or pledged to a bank. None of those is the same as a director spending their own money on the stock, so read the nature of the transaction first.
Look at the notification date too. Investors learn about a trade only when it is published, so this site measures everything from the date a filing became public, not from the day of the trade. Filings that arrive well after the three-day deadline are reported in the news as late filings. How often that happens, per year, is in late filings in numbers.
A notification shows that a trade happened. It does not show what the manager knew; directors' dealings vs insider trading explains where the line lies.
Where to find the filings
Each regulator keeps its own register. In the Netherlands it is the AFM register of transactions by managers; in Germany BaFin, in Belgium the FSMA, in Sweden Finansinspektionen, in Spain the CNMV. Each register is public, and each uses its own format. The national rules differ in the details: see the guides for the Netherlands, Germany, Belgium, Sweden and Spain.
Insider Trades brings these filings together in one searchable list, with the original filing linked on every row. How we read and classify them is set out on the methodology page. Large short positions in the same companies follow a separate rule, explained in the 0.5% short rule. How these rules differ from the US Form 4 is in insider reporting in the EU vs the US.
Checked against the regulation and the regulator’s own pages on Oct 24, 2026. This guide explains the rules; it is not legal or investment advice.
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