Market Abuse Rules and Disclosure Requirements for Issuers and Their Shareholders According to the Updated EU Market Abuse Regulation and the Financial Supervision Act of the Netherlands

The European Union (EU) Market Abuse Regulation 596/2014 (MAR) stipulates requirements regarding the disclosure of inside information. National laws of the EU Member States, based on the EU Transparency Directive 2004/109, as well as the MAR, furthermore stipulate rules regarding the disclosure of the possession of certain percentages of shares and/or votes in the issuer/listed company. All these rules and requirements aim at achieving fair market conditions for (potential) investors and the well-functioning of financial markets. In this article, an overview and discussion will be provided regarding the most important rules with respect to transparency in the MAR and in the Financial Supervision Act applicable in the Netherlands, especially in light of the (upcoming) changes in this respect in the MAR implemented via the EU Listing Act 2024/2809.