Insider lists
Insider lists

The following Corporate guidance note provides comprehensive and up to date legal information covering:

  • Insider lists
  • Brexit impact
  • Background
  • Applicable law and regulation
  • Market Abuse Regulation and Brexit
  • The requirement to keep an insider list
  • Format of an insider list
  • Updating the insider list
  • Disclosure of insider list to FCA
  • Retention of insider lists
  • more

This Practice Note considers the obligation of an issuer who issues or proposes to issue financial instruments which are within the scope of the Market Abuse Regulation (EU) No 596/2014 (Market Abuse Regulation), or any person acting on their behalf or on their account, to keep insider lists to protect and control the dissemination of inside information.

Brexit impact

The operation of the UK listing and prospectus regime may be affected by Brexit. For further details on these and other issues, see section below on Insider lists — Market Abuse Regulation and Brexit and Practice Note: Brexit—UK listing and prospectus regime.


The Market Abuse Regulation took effect across the EU on 3 July 2016. Its stated goal is to establish a common regulatory framework on insider dealing, the unlawful disclosure of inside information and market manipulation (all forms of market abuse) as well as measures to prevent market abuse to ensure the integrity of financial markets in the EU and to enhance investor protection and confidence in those markets.

One major change introduced by the Market Abuse Regulation is the extension of the market abuse regime to a wider range of financial instruments and trading venues. It now covers financial instruments:

  1. admitted to trading on a regulated market or for which a request for admission to trading on a