Leo International Precision Health AG: Bafin imposes administrative fines

What Changed

• - Issuers domiciled in Germany with securities admitted to trading on an organised market in Germany must publish an announcement (“Hinweisbekanntmachung”) specifying the exact date and internet address at which their annual financial information wil
• The announcement on annual financial information must be published no later than four months after the end of each financial year and must be issued before the first public availability of the relevant annual financial information.
• Annual financial information must be made publicly available on the internet in addition to its disclosure in the Company Register (Unternehmensregister), and the announcement obligation relates specifically to this internet publication.
• Issuers must publish a half‑yearly financial report no later than three months after the end of each reporting period.
• Failure to publish financial reports or the required announcements, or failure to do so within the prescribed periods, constitutes a contravention of the WpHG and exposes the issuer to administrative fines.
• BaFin may impose an administrative fine for each individual contravention of these reporting and announcement obligations; the statutory maximum fine is €10 million or up to 5% of the issuer’s total revenue.

Suggested Considerations

• Map all WpHG‑related periodic reporting obligations (annual, half‑yearly, and any interim or ad‑hoc requirements) into a documented compliance calendar with responsible owners and system reminders well ahead of statutory deadlines.
• Implement a formal procedure to prepare, approve, and publish “Hinweisbekanntmachungen” that clearly specify the date and internet address of annual financial information, ensuring publication before the first public availability of the annual report and within four months of financial year‑end.
• Establish controls to guarantee that annual financial information is published both in the Company Register and on the issuer’s website, and that these publications are synchronised with the required announcements.
• Design and enforce a process for producing and publishing half‑yearly financial reports within three months after the end of each reporting period, including clear timelines for drafting, audit/review (where relevant), management approval, and technical website publication.
• Conduct a gap analysis of current financial reporting and disclosure procedures against WpHG requirements to identify any missing steps, unclear responsibilities, or weaknesses in escalation mechanisms for imminent deadline breaches.
• Integrate WpHG reporting and announcement obligations into the firm’s overall disclosure and market‑communication policy, ensuring coordination between legal, finance, investor relations, and IT (web publication) teams.

Key Dates

Who is Affected