EU extends the lighter insider-list format to all MAR issuers and replaces the 2022 standard
Issuers and their advisers must move all MAR insider lists to the alleviated format under the new Implementing Regulation before it applies
Change
On 12 June 2026 the European Commission adopted Implementing Regulation (EU) 2026/1291, replacing the 2022 standard and extending the lighter 'alleviated' insider-list format — previously only for SME-growth-market issuers — to all insider lists under Article 18 of the Market Abuse Regulation, with event-based and permanent-insider sections, mandatory electronic form for most issuers, and five-year data retention.
Why it matters
Implementing Regulation (EU) 2026/1291 repeals IR 2022/1210 and, following Regulation (EU) 2024/2809, applies the alleviated insider-list format to all lists under MAR Article 18(1) and (6). Lists use an event-based section per piece of inside information (Template 1) with obtained/ceased timestamps per person, or a separate permanent-insiders' section (Template 2) for those with access to all inside information at all times. Article 18(1) lists must be electronic with restricted access, accurate updates and version history; SME-growth-market issuers are exempt from electronic form if completeness, confidentiality and integrity are preserved. Third-party service providers are represented by a single named contact, and insider personal data is retained for no more than five years after a person leaves the list. The Regulation is directly applicable and enters into force on the twentieth day after its 15 June 2026 publication.
Implications
- — Issuers, emission-allowance market participants, auction platforms, auctioneers and auction monitors, and persons acting on their behalf (including advisers, accountants and credit rating agencies), must migrate their MAR insider lists to the alleviated format in Templates 1 and 2 before the Regulation enters into force — the format that previously applied only to SME-growth-market issuers now governs all Article 18 insider lists, replacing the 2022 templates.
- — Compliance teams must structure insider lists as an event-based section per piece of inside information, recording the date and time each person obtained and ceased access, and adding a new section whenever new inside information is identified — or maintain a separate permanent-insiders' section for those with access to all inside information at all times, who must then not also appear in the event-based sections.
- — Issuers subject to Article 18(1) must keep insider lists in electronic form with access restricted to identified persons, accurate updating and retained previous versions, and transmit them by the electronic means each competent authority specifies — SME-growth-market issuers are exempt from the electronic-form requirement only if completeness, confidentiality and integrity are otherwise ensured.
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