Key dates
- 5 June 2026
- Certain amendments in sample insider policies apply (e.g., enhanced disclosures)
- Within 3 trading days Deadline
- PDMRs must report securities transactions to issuer and AMF
- 30 calendar days prior to annual/interim results publication
- Statutory blackout period for PDMRs
- 15 calendar days prior to quarterly financial info publication
- Recommended blackout for insiders per AMF guidance
Suggested considerations
- Review and update insider trading policies to align with AMF Position-Recommendation No. 2016-08, including clear inside information definitions, blackout notifications, and extensions to all insiders.
- Implement or strengthen training on MAR prohibitions, insider network risks, and whistleblowing mechanisms, especially for those handling M&A, results announcements, or advisor roles.
- Monitor and log gifts, donations, transactions in derivatives/index products, and PDMR dealings; notify insiders of blackouts via Insider Trading Committee.
- Enhance surveillance for coordinated trading patterns pre-announcements (e.g., takeover bids, results).
- For listed firms: Submit periodic/ongoing disclosures outside transactions via AMF portal and ensure compliance function oversees disciplinary measures.
What changed
This is an enforcement decision, not a regulatory amendment, so there are no new rules or requirements introduced. It reaffirms existing obligations under MAR Articles 7 (prohibition of insider dealing), 8 (unlawful disclosure of inside information), 10 (public disclosure of inside information), 14 (abuse of inside information), 17 (fair presentation and disclosure), and 19 (PDMR transactions), as well as AMF General Regulations Articles 223-9 and 221-3.
Compliance impact
Urgency: Medium. This reinforces longstanding MAR rules without new mandates, but the acquittal of two individuals signals AMF's focus on provable evidence, reducing overreach risks while heightening scrutiny on networks. It matters amid rising organized crime threats (AMF 2024 report), prompting immediate policy reviews to avoid fines, especially with EU MAR amendments (Regulation 2024/2809 effective 4 Dec 2024).