ESMA is consulting on its required review of MAR. Its paper looks at many issues including:
- whether to include spot FX within MAR;
- differing concepts of inside information and delayed disclosure of it;
- whether the trading ban and insider lists provisions are appropraite for PDMRs; and
- cross-border enforcement of sanctions.
ESMA asks for comments by 29 November and will be reporting to the Commission by spring 2020.