Earlier in October of this year, ESMA finalised its draft Implementing Technical Standards earlier, extending the alleviated insider list format (which was previously reserved only for SME Growth Market issuers) to all EU issuers under the amended Market Abuse Regulation. The change has immediate operational implications for EU and Malta‑listed issuers and aims to cut administrative burden while preserving effective supervision.
What is changing and why it matters
ESMA has consolidated five insider‑list templates into three:
- All issuers will use an event‑based section.
- Where appropriate, all issuers may use a permanent insiders section.
- SME Growth Market issuers under the simplified regime may use a third template for persons with regular access.
Data fields have been streamlined to minimise the input of personal data. For instance, personal phone number and home address fields have been removed, while the professional phone field remains; and identification is via National Identification Number (NIN) where applicable, otherwise date of birth (DOB).
Treatment of advisers and other third‑party providers
Issuers should include one natural contact person per external provider with access to inside information and record the provider’s company details within the “function and reason for being insider” field. Advisers are expected to keep their own insider lists of staff who accessed the issuer’s information.
Format, record‑keeping, and transmission
For those lists required by Article 18(1) of the MAR, issuers must keep insider lists electronically with restricted access, accuracy controls, and versioning. SME Growth Market issuers under the simplified regime may use non‑electronic formats if completeness, confidentiality, and integrity are ensured.
Once adopted by the Commission, the new Regulation will repeal and replace the current implementing regulation, consolidating all templates. Most Listing Act provisions will apply from mid‑2026, and issuers should use this as an opportunity to refresh their insider‑list governance.
Key takeaways for Malta issuers
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