The NSSMC developed the Procedure for disclosing information about legal transactions by management: discussions with the market are set to begin

As part of the implementation of a Regulation of the European Parliament and of the Council of the EU, at its meeting on 31 October, the Commission approved the draft Resolution “On Approval of the Procedure for Disclosing Information about Legal Transactions by Management.” The document was submitted for discussion to market participants.

In particular, the Procedure, which is to come into force on 01 January 2026, provides for the following:

• establishing requirements for interaction between persons performing management functions at an issuer of financial instruments and persons closely related to them in the process of notifying the issuer and the Commission of any transactions with shares, debt securities, or other related financial instruments;
• the obligation to notify is imposed if the total amount of transactions of such persons during a calendar year reaches UAH 200,000;
• determining the requirements for the content, form, and procedure for submitting such notifications, as well as for disclosing information about transactions of managers by issuers of financial instruments;
• rules are defined for managers of an issuer and related persons regarding the conclusion of transactions during the so-called closed period – 30 days before the publication of the issuer’s annual or interim financial statements.

The requirements of this Procedure apply only to issuers of financial instruments who applied for or consented to the admission of their instruments to trading on a regulated market, as well as to those whose instruments are admitted or submitted for admission to trading on an MTF or OTF, if they are traded exclusively on these facilities.

The Procedure applies to financial instruments, in particular shares, debt securities (corporate bonds, bank deposit certificates, bonds of international financial organizations, financial agricultural notes), as well as other related instruments – option certificates, stock warrants, and derivative contracts whose underlying asset is the issuer’s shares or debt securities.

We welcome market participants to join the discussion. Proposals and comments will be accepted until 28 November at the following email addresses: [email protected] and [email protected].

The Procedure is available by following the link.