Disclosure of inside information and delay of disclosure at intermediate steps in a protracted process

The amendments made by the Listing Act^[1] to the Market Abuse Regulation (EU) 596/2014 (MAR) on the disclosure and delay of disclosure of inside information related to the intermediate steps in a protracted process will apply from 5 June 2026. In the future, with regard to inside information concerning an intermediate stage in a protracted process, the issuer must only disclose the final circumstances or final event of the protracted process. The disclosure of information must take place as soon as possible after the final circumstances or events have occurred. In these situations, the issuer is not required to make a decision to delay the disclosure of inside information. A condition for non-disclosure of inside information related to the intermediate stages in a protracted process is that the confidentiality of the information can be maintained.

The Financial Supervisory Authority (FIN-FSA) will monitor the adoption of a Commission delegated act on the matter. The FIN-FSA expects the delegated act to be published in early 2026. The delegated act will specify, by way of an exemplary list, the final events and final circumstances of a protracted process and, for each event or circumstance, the moment at which it is deemed to have occurred and must be publicly disclosed.

The FIN-FSA will update its website, inform market participants through a Market Newsletter and, if necessary, organise a webinar on the topic after the publication of the delegated act.

Questions related to the interpretation of MAR

If you are uncertain about any matter related to the interpretation of MAR, we kindly ask you to contact the FIN-FSA by email at Markkinat(at)finanssivalvonta.fi instead of contacting us by phone. MAR matters are handled centrally by the FIN-FSA’s MAR team, consisting of Pia Ovaska, Rickard Sandell and Vili Kauramäki.

For further information, please contact:

Vili Kauramäki, Legal Advisor, vili.kauramaki(at)finanssivalvonta.fi, tel. +358 9 183 5095
Pia Ovaska, Chief Legal Advisor, pia.ovaska(at)finanssivalvonta.fi, tel. +358 9 183 5296
Rickard Sandell, Senior Legal Advisor, rickard.sandell(at)finanssivalvonta.fi or tel. +358 9 183 5353.

^{[1] Regulation of the Eurpean Parliament and of the Council (EU) 2024/2809}