Issuers in the European Union ("EU") and any persons
acting on their behalf or for their account must maintain
procedures for drawing up and updating insider lists consistent
with the EU's Market Abuse Regulation (MAR)1.
It is always the issuer who is fully
responsible for complying with MAR and who, therefore, must always
retain access to the insider list, even if a person acting on
behalf of the issuer, such as an advisor, assumes the task of
maintaining the insider list.
CIR 2022/12102 includes five standard templates
for reporting the personal details of persons with access to inside
information. Each template features the minimum information that
must be collected as part of the record-keeping requirements to be
compliant with MAR.
