The FIN-FSA reminds issuers and parties acting on their behalf or on their account of the changed information requirements for insider lists. The FIN-FSA has updated the insider list guidelines on its website and published new example templates in accordance with Commission Implementing Regulation (EU) 2026/1291.

The key change is that the amount of personal information to be included in insider lists has decreased. For example, insider lists no longer includes names at birth, personal phone numbers or home addresses. In the future, an insider list will include each person’s name, work phone number, function and reason for being an insider, the date and time when the person obtained access and ceased to have access to inside information, and their personal identification number or date of birth. In addition, the information of a person acting as a contact person for a third-party service provider may be included.

At the same time, the insider list templates have been harmonised. The previous separate insider list templates for the SME Growth Market (First North) have been removed and, in the future, the same project-specific insider list and permanent insider templates will be used for both the regulated market and the SME Growth Market. There will now be two templates published on the website instead of the previous five.

The timely establishment and reliable maintenance of an insider list is emphasised due to amendments made to Article 17 of MAR, as after 5 June 2026 the issuer will no longer be obliged to make a decision to delay the disclosure of inside information related to the intermediate steps in a protracted process.

For further information, please contact:

• Hermanni Teräväinen, Chief Supervisor, hermanni.teravainen(at)fiva.fi or tel. +358 9 183 5346