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LISTING ACT: Market Abuse
Two delegated regulations relating to the Listing Act changes to the EU Market Abuse Regulation (MAR) have been published in the Official Journal of the EU.
The first delegated regulation, which entered into force on 19 July 2026:
- supplements the changes made to Article 17 of MAR concerning the disclosure of inside information in protracted processes and sets out a non-exhaustive list of final events or circumstances in protracted processes that trigger a disclosure obligation and the applicable timing; and
- sets out a non-exhaustive list of situations where inside information is in contrast with the latest public announcement or other type of communication and gives examples of what constitutes an “other type of communication”. This relates to the amendment made to Article 17(4) of MAR by the Listing Act which specifies the conditions which must be met before there can be a delay in disclosure of inside information.
The second delegated regulation, which enters into force on 5 August 2026, includes:
- the expanded exemptions allowing persons discharging managerial responsibilities (PDMRs) to trade during closed periods (to include financial instruments other than shares);
- a list of designated trading venues subject to the cross-border order data exchange mechanism; and
- updated indicators of market manipulation.
European Single Access Point (ESAP)
From 10 July 2026, Officially Appointed Mechanisms (OAMs) and National Competent Authorities (NCAs) will begin to provide to the ESAP information and metadata collected from entities. This is the first phase in the implementation of the ESAP platform which will provide access to financial and sustainability information about entities and their products. The platform will become accessible to the public by July 2027.
Information in scope of the first phase of ESAP includes information relating to the Transparency Directive and the Prospectus Regulation. The Central Bank of Ireland has, however, postponed the collection of ESAP metadata under the Prospectus Regulation until 15 October 2026.
Revised Euronext Harmonised Rules
A revised version of the Euronext Harmonised Rulebook I took effect from 29 June 2026. The Rulebook has been revised to amend article 5701/3 Off Order Book Transactions in respect of the time limit for validating Off Order Book Transactions, which is extended from 15 minutes to the end of the trading session.
FRC Materiality in Corporate Reporting
The UK Financial Reporting Council (FRC) has published guidance on applying materiality in annual reports. The guidance notes, amongst other things, that:
- directors should focus disclosures on information that could reasonably influence the decisions of shareholders and other primary users;
- excessive immaterial disclosure can obscure key messages; and
- companies should make entity-specific materiality judgements, taking account of both quantitative and qualitative factors.
The guidance also includes a set of FAQs and an illustrative six-step process for assessing, presenting and reviewing material information in annual reports.
T+1
ESMA has published a statement highlighting key deadlines and action points to be ready for the transition to a T+1 settlement cycle in EU financial markets (which will occur on 11 October 2027). ESMA underlines that 2026 is a critical year for market participants to finalise their preparations and notes that the first regulatory deadline is on 7 December 2026 for allocations and confirmations processes.
This article contains a general summary of developments and is not a complete or definitive statement of the law. Specific legal advice should be obtained where appropriate.
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