Market regulation

MAR and disclosure

MAR assessments are often made while facts are still developing and time is short. The aim is a traceable decision showing what the company knew, when it knew it and why the information was handled in a particular way.

Discuss your situation

The assignment

A process that holds together.

We assess whether information is sufficiently precise and likely to have a significant price effect.

For delayed disclosure, the company must assess the conditions, protect confidentiality, maintain insider lists and revisit the decision as facts change.

Advice may also cover disclosure and insider policies, decision logs, announcements, market soundings, training and out-of-hours readiness.

How it works

Four connected workstreams.

The precise order is adapted to the company, but decisions, documentation and communications must use the same facts.

01

Facts and timeline

Define the event, when information emerged and which decisions or external conditions remain.

02

Legal assessment

Assess precision, likely price effect, protracted processes and any basis for delayed disclosure.

03

Decision and control

Record the decision-maker, log, insider list, confidentiality and next review time.

04

Disclosure

Quality-check the announcement and coordinate distribution, website publication and follow-up.

Common pitfalls

Where otherwise sound processes lose time.

  1. 01

    Starting with whether the company wants to publish instead of whether the information is inside information.

  2. 02

    Delaying without a documented confidentiality assessment or review point.

  3. 03

    Opening the insider list too late or recording incorrect access times.

  4. 04

    Publishing legally accurate wording that does not let the market assess the event.

Questions and answers

Frequently asked questions

Concise answers to recurring questions. The details always depend on the company and the current rules.

01What is inside information?

In simplified terms, it is non-public information of a precise nature relating directly or indirectly to an issuer or instrument which, if public, would be likely to have a significant effect on price. The assessment is specific to the company and all circumstances.

02Can disclosure be delayed?

Yes, if all applicable conditions are met, including protection of legitimate interests, no misleading of the public and continued confidentiality. The conditions must remain satisfied throughout the delay.

03Who makes the decision?

Responsibility rests with the issuer. The company should have a documented internal authority structure, deputies and access to legal and financial competence. Board involvement depends on significance and internal instructions.

04How quickly must an announcement be published?

Inside information must generally be disclosed as soon as possible. Templates, distribution, website access and decision-makers should therefore be available outside office hours, with a tested backup chain.

Rules change. Check the current primary source before making a decision.

Finansinspektionen – insiderinformationEUR-Lex – konsoliderad MAR

An initial conversation

What needs to happen before the next decision?

Tell us briefly about the company, the matter and the timetable. We normally respond within one business day.