The Federal Financial Supervisory Authority (BaFin) intends to raise the reporting threshold for personal transactions by executives of listed companies and other issuers subject to reporting requirements from the current amount of EUR 20,000 to EUR 50,000 with effect from 1 January 2026.
The reporting requirement for directors’ dealings, which is intended in particular to prevent insider trading and promote transparency on the capital markets, applies to persons who perform management tasks at issuers of financial instruments affected by the legal provisions of the EU Market Abuse Regulation (MAR) and therefore have regular access to insider information. However, it also applies to spouses, registered partners, dependent children and other relatives who have been living in the same household for at least one year. It must also be observed by legal entities, fiduciary institutions (e.g. foundations) or partnerships that have a close relationship with a manager. The notification must be made to both BaFin and the issuer within three business days.
By raising the threshold for directors’ dealings, BaFin aims to reduce the organisational and financial burden on the executives concerned and the respective issuers. The higher threshold is made possible by the EU Listing Act, which aims, among other things, to reduce the ongoing costs of a stock exchange listing. The measure is also intended to strike an appropriate balance between transparency and the number of notifications.
The last adjustment to the threshold for the reporting obligation was made on 1 January 2020, from EUR 5,000 per calendar year to EUR 20,000, which will remain in force until 31 December 2025.
