What is a PDMR?
PDMR stands for person discharging managerial responsibilities. If you are one at a listed EU company, you report your trades in its shares, and so do the people close to you.
The definition
Article 3(1)(25) of the Market Abuse Regulation names two groups at the company that issued the shares:
- Members of its administrative, management or supervisory body: the board of directors, or the management board and the supervisory board.
- Senior executives outside those bodies who have regular access to inside information about the company and the power to take managerial decisions about its future and its prospects. Both conditions apply.
A chief financial officer who sits on the board is a PDMR through the first group. A head of strategy who sees the results early and decides on acquisitions, without a board seat, can be one through the second. A manager who sees inside information but takes no such decisions is not a PDMR, though the company may still put that person on its insider list.
Persons closely associated
Article 3(1)(26) extends the duty to people and entities close to the PDMR:
- A spouse, or a partner that national law treats as equal to a spouse.
- A dependent child, as national law defines it.
- A relative who has shared the PDMR's household for at least one year on the date of the trade.
- A company, trust or partnership that a PDMR or one of the persons above manages or controls, that was set up for their benefit, or whose economic interests match theirs.
So if a director holds shares through a personal holding company, that company reports its trades as a closely associated person. The filing then names the director as well.
What follows from it
- The PDMR and each closely associated person report their own trades in the company's shares, debt and linked derivatives, within three business days, once the trades in a calendar year pass the national threshold (the MAR guide covers the details).
- The PDMR may not trade during the closed period of 30 days before the company's results. That ban covers the PDMR, not the closely associated persons.
- The company keeps a list of its PDMRs and their closely associated persons, and tells each PDMR in writing about these duties (Article 19(5)). The PDMR in turn informs their closely associated persons in writing.
The US term
US law uses a different group. Directors, officers and owners of more than 10% of a class of shares are Section 16 insiders and file Forms 3, 4 and 5. In the EU, a large shareholder is not a PDMR for that reason alone.
PDMR filings on this site
Insider Trades lists the filings of PDMRs and their closely associated persons from five EU registers, with the role as the register gives it. Each country adds its own details: see the guides for the Netherlands, Germany, Belgium, Sweden and Spain. When several PDMRs of one company buy within 90 days, the purchases appear together in buyer clusters (what is cluster buying?).
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.
More guides
- EUMAR art. 19What is a MAR Article 19 notification?How directors' dealings are reported in the EU under the Market Abuse Regulation: who must report, the deadline, the threshold, what a notification contains and where to find them.
- USSEC Form 4How to read an SEC Form 4A field-by-field guide to the Form 4 that US company insiders file with the SEC: who files it, the two-day deadline, the transaction codes, and the 10b5-1 checkbox.
- USSTOCK ActWhat members of Congress must disclose about their tradesHow the STOCK Act makes members of the US Congress report their stock trades: the 30- and 45-day deadlines, the $1,000 threshold, the amount ranges, and what is left out.
- EUNetherlands · AFMWhen does an insider have to report a trade in the Netherlands?Who reports trades to the Dutch AFM, the three-day deadline, the €20,000 threshold, the extra Wft duty for board members, and where you find the filings.
- EUGermany · BaFinWhen does an insider have to report a trade in Germany?Directors' dealings in Germany: who reports to BaFin, the three-day deadline, the €50,000 threshold that applies since 1 January 2026, and where the filings appear.
- EUBelgium · FSMAWhen does an insider have to report a trade in Belgium?Managers' transactions in Belgium: who reports to the FSMA through eMT, the three-day deadline, the €20,000 threshold, and why the issuer has to confirm a filing first.
- EUSweden · FIWhen does an insider have to report a trade in Sweden?Insider trades in Sweden: who reports to Finansinspektionen, the three-day deadline, the €20,000 threshold, and how the insider register (insynsregistret) works.
- EUSpain · CNMVWhen does an insider have to report a trade in Spain?Managers' transactions in Spain: who reports to the CNMV, the three-day deadline, the €20,000 threshold in Article 230 of the Securities Market Act, and where the filings appear.
- EUMAR art. 19(11)What is a closed period?The 30 days before a listed EU company publishes its results, when its managers may not trade its shares: the rule, the exceptions, the Listing Act changes and the US blackout.
- USSEC Section 16Form 3, 4 and 5: what's the difference?The three SEC forms that US company insiders file: Form 3 when they become an insider, Form 4 after a trade, Form 5 once a year. Who files each one, and by when.
- USSEC Rule 10b5-1What is a 10b5-1 plan?How US insiders trade through a pre-arranged plan under SEC Rule 10b5-1: the rule, the 2022 changes (cooling-off, certification, overlapping plans) and the Form 4 checkbox.
- USSEC Form 13FHow to read a 13F filingWho files Form 13F with the SEC, by when, and what it shows: the long positions of large US fund managers at the end of each quarter, without shorts or cash.
- USLobbying Disclosure ActHow does US lobbying disclosure work?How the US Lobbying Disclosure Act works: registration on Form LD-1, quarterly LD-2 reports with amounts rounded to $10,000, and the twice-yearly LD-203 contribution reports.
- USOGE Form 278What must the President and senior officials disclose?The OGE Form 278e financial disclosure of the US President, Vice President and senior officials, and the 278-T report of trades within 30 or 45 days.
- EUShort Selling RegulationShort positions in Europe: what is the 0.5% rule?How the EU Short Selling Regulation works: net short positions go to the regulator from 0.1% of a company's shares and become public from 0.5%, with each 0.1% step above.
- EU/USMAR vs Section 16Insider reporting in the EU vs the US: what's different?How EU and US rules on reporting insider trades compare: who reports, the three-day and two-day deadlines, the thresholds, what a filing shows and who publishes it.
- EU/USMAR art. 14 · Rule 10b-5Directors' dealings vs insider trading: what is legal?The difference between a reported directors' dealing and illegal insider trading under EU law (MAR Articles 7, 8 and 14) and US law (Rule 10b-5), with the penalties.
- EU/USLate filingsHow often are insider filings late?How many Form 4 filings, Congress trade reports and EU insider notifications arrive after the legal deadline, per year, counted from the registers on this site.
- EUNetherlands · AFMHow many insider trades are reported in the Netherlands?Managers' trades reported to the Dutch AFM, counted per year and per sector: entries in both AFM registers, companies, and open-market buys and sales.
- USSTOCK ActWhich members of Congress trade the most?Members of the US Congress ranked by the number of trades they reported for the last full calendar year, with purchases, sales and the amount ranges as filed.
- EU/USInsider salesWhy do insiders sell stock?The common reasons company insiders sell their own shares: pay in stock, tax, spreading risk, cash for a house, a pre-set 10b5-1 plan. And what research found about sales.
- USSEC Form 4Form 4 transaction codes explainedEvery transaction code on an SEC Form 4, from P and S to A, M, F, G and J, with its meaning from the SEC's own instructions, and which codes are trades at the market.
- EU/USInsider purchasesWhat is cluster buying?Cluster buying: several insiders of one company buying its shares within a short period. How this site counts a cluster: three buyers within 90 days, by filing date.
- EU/USRegistersHow to track insider trades for freeThe official free registers of insider trades: SEC EDGAR in the US, and AFM, BaFin, FSMA, FI and CNMV in Europe. What each one lets you search and download.
- EU/USResearchDo insider purchases predict stock returns?What studies of US, UK and German filings found about share returns after insiders buy, from Lakonishok and Lee to Cohen, Malloy and Pomorski, and the limits of those findings.
- USSTOCK ActCan members of Congress trade stocks?Yes: members of the US Congress may trade stocks, but must report each trade within 45 days under the STOCK Act. The late fee, and the bills to ban trading as of 31 October 2026.
- USResearchDo politicians beat the market?What studies found about the stock returns of US senators and representatives, from Ziobrowski in 2004 to studies of trades after the STOCK Act, and why the results differ.
- USOGE Form 278What stocks does Trump own?Where to find what President Trump owns: the annual OGE Form 278e with assets in value ranges, the 278-T reports of trades, and what neither form shows.
- EUMAR art. 19Biggest insider purchases in Europe this yearThe largest open-market share purchases by company insiders in the Netherlands, Germany, Belgium, Sweden and Spain this year, ranked by amount in euros.
- EUMAR art. 19(11)When do insiders buy? Purchases by monthOpen-market purchases and sales by company insiders in the Netherlands, Sweden and Spain, counted per calendar month over all full years, and how closed periods fit in.
- USSEC Form 13FWhat is Berkshire Hathaway buying?Berkshire Hathaway's largest US stock holdings from its latest Form 13F, how many positions grew, shrank, appeared or disappeared, and what the filing leaves out.
- EU/USTransparency DirectiveMajor shareholdings in the EU: the 3% and 5% ruleWhen an investor in an EU listed company must report its stake: the 5% threshold of the Transparency Directive, lower national thresholds, the deadlines, and the US Schedule 13D.
- EU/USMCPInsider trading data in Claude and ChatGPT (MCP)Connect InsiderRadar to Claude or ChatGPT over MCP: the address, the sign-in steps, and the six read-only tools for insider, Congress, 13F and lobbying filings.