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ARTICLE · 14 APRIL 2026

CJEU Confirms Insider List Notifications Can Constitute Inside Information

Lewis Silkin
Lewis Silkin
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Lewis Silkin

Lewis Silkin

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The Court of Justice of the European Union has ruled that notifying someone of their placement on an insider list with trading restrictions can itself constitute inside information under the EU Market Abuse Regulation.

European UnionFinance and Banking
Wendy Saunders
Wendy Saunders
Helen Hart
Helen Hart
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The Court of Justice of the European Union has held in Case C-363/24, Finansinspektionen v Carnegie Investment Bank AB that a communication informing a person that someone has been placed on an insider list and is prevented from trading can, in itself, constitute inside information under the EU Market Abuse Regulation (MAR). This is even where the underlying reasons for the person's inclusion on the insider list are not disclosed. The judgment also confirms that information which later proves to have been incorrect at the time it was communicated may still qualify as inside information, provided it was credible at the time and capable of conferring an economic advantage on the recipient. 

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