See Full Document Text
Official Journal EN
of the European Union L series
2026/1291 15.6.2026
COMMISSION IMPLEMENTING REGULATION(EU) 2026/1291
of 12 June 2026
laying down implementing technical standards for the application of Regulation (EU) No 596/2014 of
the European Parliament and of the Council with regard to the format of insider lists, and repealing
Commission Implementing Regulation (EU) 2022/1210
(Text with EEA relevance)
THE EUROPEAN COMMISSION,
Having regard to the Treaty on the Functioning of the European Union,
Having regard to Regulation (EU) 596/2014 of the European Parliament and of the Council of 16 April 2014 on market
abuse (market abuse regulation) and repealing Directive 2003/6/EC of the European Parliament and of the Council and
Commission Directives 2003/124/EC, 2003/125/EC and 2004/72/EC(1), and in particular Article 18(9), third
subparagraph, thereof,
Whereas:
(1) Pursuant to Article 18 of Regulation (EU) No 596/2014, issuers, emission allowance market participants, auction
platforms, auctioneers, auction monitors (‘entities’) and any person acting on their behalf or on their account are
required to draw up and promptly update a list of all persons who have access to inside information and who are
working for them under a contract of employment, or otherwise performing tasks through which they have access
to inside information, including advisers, accountants or credit rating agencies (‘insider list’) in accordance with a
precise format. The establishment of a precise format, including the use of standard templates, should facilitate the
uniform application of the requirement to draw up and promptly update insider lists. The establishment of such a
precise format should also ensure that competent authorities are provided with the information necessary to fulfil
the task of protecting the integrity of the financial markets and investigate possible market abuse.
(2) Article 18(9) of Regulation (EU) No 596/2014 empowered the Commission to determine the precise format of
insider lists and the format for updating insider lists which the Commission did in Commission Implementing
Regulation (EU) 2016/347(2). Regulation (EU) 2019/2115 of the European Parliament and of the Council(3)
amended Article 18 of Regulation (EU) No 596/2014 to introduce the possibility for issuers whose financial
instruments are admitted to trading on an SME growth market to maintain only a list of persons who, due to the
nature of their function or position within the issuer, have regular access to inside information, while giving Member
States the option of introducing a requirement for those issuers to provide more extensive insider lists that include all
persons who have access to inside information, where justified by specific national market integrity concerns.
Regulation (EU) 2019/2115 also introduced in Article 18(6) of Regulation (EU) No 596/2014 a new empowerment
for the Commission to determine the format of those more extensive insider lists and required that such a format be
proportionate and represent a lighter administrative burden compared to the format determined in accordance with
Article 18(9) of Regulation (EU) No 596/2014 (‘alleviated format’). The Commission acted upon that empowerment
(1) OJ L 173, 12.6.2014, p. 1, ELI: http://data.europa.eu/eli/reg/2014/596/oj.
(2) Commission Implementing Regulation (EU) 2016/347 of 10 March 2016 laying down implementing technical standards with regard
to the precise format of insider lists and for updating insider lists in accordance with Regulation (EU) No 596/2014 of the European
Parliament and of the Council (OJ L 65, 11.3.2016, p. 49, ELI: http://data.europa.eu/eli/reg_impl/2016/347/oj).
(3) Regulation (EU) 2019/2115 of the European Parliament and of the Council of 27 November 2019 amending Directive 2014/65/EU
and Regulations (EU) No 596/2014 and (EU) No 2017/1129 as regards the promotion of the use of SME growth markets (OJ L 320,
11.12.2019, p. 1, ELI: http://data.europa.eu/eli/reg/2019/2115/oj).
ELI: http://data.europa.eu/eli/reg_impl/2026/1291/oj 1/8EN
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by adopting Commission Implementing Regulation (EU) 2022/1210(4), which repealed Implementing Regulation
(EU) 2016/347. Regulation (EU) 2024/2809 of the European Parliament and of the Council(5) further amended
Regulation (EU) No 596/2014 by deleting the empowerment in Article 18(6) and replacing the empowerment in
Article 18(9) with a new empowerment for the Commission to review the implementing technical standards on the
format of the insider lists to extend the use of the alleviated format to all insider lists referred to in Article 18(1)
and (6), first and second subparagraphs. It follows that Implementing Regulation (EU) 2022/1210 should be
repealed and replaced by a new Regulation.
(3) To ensure that the drawing up and updating of insider lists impose only a limited administrative burden, while
enabling competent authorities to identify persons that have access to inside information and establish links between
insiders and persons involved in suspicious trading, the insider lists referred to in Article 18(1) and (6), first and
second subparagraphs, of Regulation (EU) No 596/2014 should be drawn up and updated in accordance with the
alleviated format that has so far applied to the insider lists referred to in Article 18(6), second subparagraph, of that
Regulation.
(4) Pursuant to Article 18 of Regulation (EU) No 596/2014, persons acting on behalf or on the account of an entity are
to draw up and promptly update a list of all persons who have access to inside information that concerns that entity
and who are working for them under a contract of employment, or are otherwise performing tasks through which
they have access to inside information. To avoid unnecessary duplication of data and to minimise administrative
burdens, where a legal person acts on behalf or on the account of an entity (‘third-party service provider’) and has
access to inside information which directly concerns that entity, that entity should include in its insider list the
details of only one natural person acting as a contact person for that third-party service provider.
(5) Since multiple pieces of inside information can exist within an entity at the same time, the insider lists referred to in
Article 18(1) and (6), second subparagraph, of Regulation (EU) No 596/2014 should identify the exact piece of
inside information to which the persons referred to in Article 18(1) of Regulation (EU) No 596/2014 have access. To
that end, those insider lists should contain a section specific to each piece of inside information (the ‘event-based
section’). Each event-based section should list all persons having access to a specific piece of inside information and,
for each person, indicate the date and time when the insider obtained access to that piece of inside information and
the date and time when the insider ceased to have access to that piece of inside information. A new section should
be added to the insider lists referred to in Article 18(1) and (6), second subparagraph, of Regulation (EU)
No 596/2014 upon the identification of a new piece of inside information.
(6) To reduce administrative burdens and avoid duplicative entries in the insider lists referred to in Article 18(1) and (6),
second subparagraph, of Regulation (EU) No 596/2014 with respect to persons who, due to the nature of their
function or position within an entity, have access to all inside information at all times (‘permanent insiders’), it
should be possible to list those persons in a supplementary section of the insider list (the ‘permanent insiders’
section’). As that section should be of a different nature to the event-based sections of the insider list, it should not
be created each time upon the identification of a new piece of inside information. That section should rather specify
the date and time when a permanent insider obtained and ceased to have access to all inside information at all times.
(4) Commission Implementing Regulation (EU) 2022/1210 of 13 July 2022 laying down implementing technical standards for the
application of Regulation (EU) No 596/2014 of the European Parliament and of the Council with regard to the format of insider lists
and their updates (OJ L 187, 14.7.2022, p. 23, ELI: http://data.europa.eu/eli/reg_impl/2022/1210/oj).
(5) Regulation (EU) 2024/2809 of the European Parliament and of the Council of 23 October 2024 amending Regulations
(EU) 2017/1129, (EU) No 596/2014 and (EU) No 600/2014 to make public capital markets in the Union more attractive for
companies and to facilitate access to capital for small and medium-sized enterprises (OJ L, 2024/2809, 14.11.2024, ELI: http://data.
europa.eu/eli/reg/2024/2809/oj).
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An entity that decides to draw up and keep up to date a permanent insiders’ section, should not include the
permanent insiders listed therein also in the event-based sections of the insider list, since those insiders are deemed
to have access to all inside information at all times.
(7) Since Article 18(6), first subparagraph, of Regulation (EU) No 596/2014 allows issuers whose financial instruments
are admitted to trading on an SME growth market to include in their insider lists only those persons who, due to the
nature of their function or position within the issuer, have regular access to inside information, the insider lists
referred to in that provision should not include separate event-based sections. Instead, they should list all insiders
having regular access to inside information and, for each of them, specify the date and time when the insider
obtained and ceased to have regular access to inside information. It follows that that list of insiders should not be
amended each time upon the emergence of a specific piece of inside information, unless the list of insiders having
regular access to inside information changes.
(8) This Regulation respects the fundamental rights and observes the principles recognised by the Charter of
Fundamental Rights of the European Union, and notably the right to protection of personal data. The processing of
personal data for the purposes of this Regulation should be carried out in accordance with Union law on the
protection of personal data. In that regard, any processing of personal data performed by competent authorities in
application of this Regulation should be carried out in accordance with Regulation (EU) 2016/679 of the European
Parliament and of the Council(6).
(9) To ensure that the insider lists can be made available to the competent authority as soon as possible upon request and
that they can always be updated without delay, insider lists should be kept in an electronic form. The electronic form
should ensure that the information included in the insider list is kept confidential. To avoid a disproportionate
administrative burden on issuers whose financial instruments are admitted to trading on an SME growth market,
such issuers should not be required to draw up and keep up to date the insider list in an electronic form, provided
that the completeness, confidentiality and integrity of the information included in the insider list is ensured.
(10) To reduce the administrative burden associated with the transmission of insider lists to the competent authority, the
specific electronic means of transmission should be determined by the competent authorities themselves, while
ensuring the confidentiality of those lists.
(11) The European Data Protection Supervisor was consulted in accordance with Article 42(1) of Regulation
(EU) 2018/1725 of the European Parliament and of the Council(7) and delivered formal comments on 4 February
2026.
(12) This Regulation is based on the draft implementing technical standards submitted to the Commission by the
European Securities and Markets Authority (ESMA).
(6) Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with
regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data
Protection Regulation) (OJ L 119, 4.5.2016, p. 1, ELI: http://data.europa.eu/eli/reg/2016/679/oj).
(7) Regulation (EU) 2018/1725 of the European Parliament and of the Council of 23 October 2018 on the protection of natural persons
with regard to the processing of personal data by the Union institutions, bodies, offices and agencies and on the free movement of
such data, and repealing Regulation (EC) No 45/2001 and Decision No 1247/2002/EC (OJ L 295, 21.11.2018, p. 39, ELI: http://data.
europa.eu/eli/reg/2018/1725/oj).
ELI: http://data.europa.eu/eli/reg_impl/2026/1291/oj 3/8EN
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(13) ESMA has conducted open public consultations on the draft implementing technical standards on which this
Regulation is based and requested the advice of the Securities Markets Stakeholder Group established by Article 37
of Regulation (EU) No 1095/2010 of the European Parliament and of the Council(8). ESMA did not analyse the
potential related costs and benefits as that would have been disproportionate in relation to the expected impact on
market participants of the amendments,
HAS ADOPTED THIS REGULATION:
Article 1
Insider list referred to in Article 18(1) of Regulation (EU) No 596/2014
1. The insider list referred to in Article 18(1) of Regulation (EU) No 596/2014 shall contain a section specific to each
piece of inside information and shall be drawn up and kept up to date in accordance with Template 1 of Annex I to this
Regulation.
2. By way of derogation from paragraph 1, persons who, due to the nature of their function or position, have access to
all inside information at all times may be listed separately in a permanent insiders’ section of the insider list. That section
shall be drawn up and kept up to date in accordance with Template 2 of Annex I to this Regulation. Where a permanent
insiders’ section is drawn up and kept up to date, the persons listed therein shall not be included in the section of the
insider list referred to in paragraph 1.
3. The insider list referred to in Article 18(1) of Regulation (EU) No 596/2014 shall be kept in an electronic form that, at
all times, ensures that:
(a) access to the insider list is restricted to clearly identified persons that need that access due to the nature of their
function or position;
(b) the information included is accurate and kept up to date;
(c) previous versions of the insider list are accessible.
4. The competent authority shall specify on its website the electronic means by which the insider list referred to in
Article 18(1) of Regulation (EU) No 596/2014 is to be transmitted to the competent authority. Those electronic means
shall ensure that the completeness, integrity and confidentiality of the information contained in that insider list are
maintained at all times during the transmission of that list to the competent authority.
5. Issuers, emission allowance market participants, auction platforms, auctioneers, auction monitors and any person
acting on their behalf or on their account shall retain the personal data relating to persons on the insider list that they draw
up and update pursuant to Article 18(1) of Regulation (EU) No 596/2014 for no longer than five years after a person ceased
to be on their insider list.
A competent authority that received an insider list transmitted pursuant to Article 18(1), point (c), of Regulation (EU)
No 596/2014 shall retain the personal data relating to persons on that insider list for no longer than necessary for
performing its supervisory tasks, subject to regular review of the need to retain those data.
Article 2
Insider lists referred to in Article 18(6) of Regulation (EU) No 596/2014
1. The insider lists referred to in Article 18(6), first subparagraph, of Regulation (EU) No 596/2014 shall be drawn up
and kept up to date in accordance with the Template set out in Annex II to this Regulation.
(8) Regulation (EU) No 1095/2010 of the European Parliament and of the Council of 24 November 2010 establishing a European
Supervisory Authority (European Securities and Markets Authority), amending Decision No 716/2009/EC and repealing Commission
Decision 2009/77/EC (OJ L 331, 15.12.2010, p. 84, ELI: http://data.europa.eu/eli/reg/2010/1095/oj).
4/8 ELI: http://data.europa.eu/eli/reg_impl/2026/1291/ojEN
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2. The insider lists referred to in Article 18(6), second subparagraph, of Regulation (EU) No 596/2014 shall contain a
section specific to each piece of inside information and shall be drawn up and kept up to date in accordance with Template
1 of Annex I to this Regulation.
By way of derogation from the first subparagraph, persons who, due to the nature of their function or position within the
issuer, have access to all inside information at all times may be listed separately in a permanent insiders’ section of the
insider list. That section shall be drawn up and kept up to date in accordance with Template 2 of Annex I to this
Regulation. Where a permanent insiders’ section is drawn up and kept up to date, the persons listed therein shall not be
included in the section of the insider list referred to in the first subparagraph.
3. The insider lists referred to in Article 18(6) of Regulation (EU) No 596/2014 shall be kept in any form that ensures
that the completeness, integrity and confidentiality of the information contained in those lists are maintained at all times
during the transmission of those lists to the competent authority.
4. Issuers whose financial instruments are admitted to trading on an SME growth market shall retain the personal data
relating to persons on the insider list that they draw up and update pursuant to Article 18(6) of Regulation (EU)
No 596/2014 for no longer than five years after a person ceased to be on their insider list.
A competent authority that received an insider list transmitted pursuant to Article 18(6), third subparagraph, of Regulation
(EU) No 596/2014 shall retain the personal data relating to persons on that insider list for no longer than necessary for
performing its supervisory tasks, subject to regular review of the need to retain those data.
Article 3
Repeal
Implementing Regulation (EU) 2022/1210 is repealed.
References to the repealed Regulation shall be construed as references to this Regulation.
Article 4
Entry into force
This Regulation shall enter into force on the twentieth day following that of its publication in the Official Journal of the
European Union.
This Regulation shall be binding in its entirety and directly applicable in all Member States.
Done at Brussels, 12 June 2026.
For the Commission
The President
Ursula VON DER LEYEN
ELI: http://data.europa.eu/eli/reg_impl/2026/1291/oj 5/8ANNEX I
TEMPLATE 1
Template for the insider lists referred to in Article 1(1) and Article 2(2), first subparagraph
Description of the specific piece of inside information to which this section relates to:
Date and time of creation of this section(i.e. when the specific piece of inside information was identified): [yyyy-mm-dd, hh:mm UTC (Coordinated Universal Time)]
Date and time of the last update of this section: [yyyy-mm-dd, hh:mm UTC (Coordinated Universal Time)]
Date of transmission to the competent authority: [yyyy-mm-dd]
Surname(s)of the
First name(s)of the
insider
insider
(in the case of third-
(in the case of third-party Professional telephone Obtained Ceased
party service
service providers, the first number(s) (the date and time when the (the date and time when the National Identification
providers, the Function and reason for
name(s) of the natural (work direct telephone insider obtained access to the insider ceased to have access Number(if applicable) or
surname(s) of the being insider
person acting as a line and work mobile specific piece of inside to the specific piece of otherwise Date of Birth
natural person acting
contact person for that numbers) information) inside information)
as a contact person
third-party service
for that third-party
provider)
service provider)
[Text] [Text] [Numbers (no space)] [Text describing role, [yyyy-mm-dd, hh:mm [yyyy-mm-dd, hh:mm [Number and/or text or
function and reason for UTC] UTC] yyyy-mm-dd for the
being on this list, includ date of birth]
ing the company name
and address in the case of
third-party service provi
ders]
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EN
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15.6.2026TEMPLATE 2
Template for the permanent insiders’ section referred to in Article 1(2) and Article 2(2), second subparagraph
Date and time of creation of the permanent insiders’ section: [yyyy mm-dd, hh:mm UTC (Coordinated Universal Time)]
Date and time of the last update of the permanent insiders’ section: [yyyy-mm-dd, hh:mm UTC (Coordinated Universal Time)]
Date of transmission to the competent authority: [yyyy-mm-dd]
First name(s)of the Surname(s)
insider of the insider
(in the case of third- (in the case of third- Professional telephone Obtained Ceased
party service providers, party service providers, number(s) (the date and time when the (the date and time when the National Identification
Function and reason for
the first name(s) of the the surname(s) of the (work direct telephone insider obtained access to all insider ceased to have Number(if applicable) or
being insider
natural person acting natural person acting as line and work mobile inside information at all access to all inside otherwise Date of Birth
as a contact person for a contact person for numbers) times) information at all times)
that third-party service that third-party service
provider) provider)
[Text] [Text] [Numbers (no space)] [Text describing role, [yyyy-mm-dd, hh:mm [yyyy-mm-dd, hh:mm [Number and/or text or
function and reason for UTC] UTC] yyyy-mm-dd for the date
being in this section, of birth]
including the company
name and address in the
case of third-party ser
vice providers]
ELI:
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ENANNEX II
Template for the insider list referred to in Article 2(1)
Date and time of creation of the insider list: [yyyy-mm-dd, hh:mm UTC (Coordinated Universal Time)]
Date and time of the last update of the insider list: [yyyy-mm-dd, hh:mm UTC (Coordinated Universal Time)]
Date of transmission to the competent authority: [yyyy-mm-dd]
First name(s)of the Surname(s)of the
insider insider
(in the case of third- (in the case of third-
Ceased
party service party service Professional telephone Obtained
(the date and time when National Identification
providers, the first providers, the number(s)(work direct Function and reason for (the date and time when the
the insider ceased to have Number(if applicable) or
name(s) of the natural surname(s) of the telephone line and work being insider insider obtained regular
regular access to inside otherwise Date of Birth
person acting as a natural person acting mobile numbers) access to inside information)
information)
contact person for as a contact person
that third-party for that third-party
service provider) service provider)
[Text] [Text] [Numbers (no space)] [Text describing role, [yyyy-mm-dd, hh:mm [yyyy-mm-dd, hh:mm [Number and/or text or yyyy-
function and reason for UTC] UTC] mm-dd for the date of birth]
being on this list,
including the company
name and address in the
case of third-party ser
vice providers]
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