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  • Graham Ward-Thompson

Independent Research on MAR

Whilst most commentators have concentrated on how the insider list rules contained in the Market Abuse Regulations have been taken up by large quoted companies, the fact is that small and mid-cap companies make up the vast majority of quoted companies in the UK (about 93%).

Their larger brethren (the FTSE 350) have generally introduced new computer based “software as a service” based systems to deal with the maintenance of insider lists and ensure they can deliver complete lists within the usual 24-hour deadline given by the FCA.

The Quoted Companies Alliance and Thomson Reuters Practical Law have recently surveyed QCA members on their experience with insider lists. The results of the poll can be viewed here.

In Summary

57% have delayed disclosing inside information (which would require the establishment of a project list) – one was asked for a written explanation as to how the delay passed the MAR tests;

14% have been asked for a copy of their insider list; and

62% have labelled their financial results information as containing inside information (although most of them were unsure and so adopted a cautious approach)

64% maintain confidential/project lists in addition to the insider list required by MAR


In our experience the FCA’s interest in smaller companies (as evidenced by the number being asked for a copy of their insider list) matches their interest in larger companies.

The fact that 62% have taken the view that financial reports contain inside information seems of more interest and may indicate an overly cautious approach to MAR which would therefore drive more questions from the FCA.

Finally, only 4% of companies reviewed the procedures used to identify whether inside information existed. This statistic is worryingly low. Many larger companies have established senior committees to review the position on a regular basis and it seems unlikely that smaller companies would have already had such robust procedures in place prior to MAR.


Howells solution IMTrack helps companies maintain their insider and projects lists efficiently and minimises worry. The system:

  • Is based on secure servers fully encrypted to the highest standards using UK based data centres

  • Supports the establishment of insider lists and confidential project lists and easy switching between the two

  • Avoids the worry of lost/overwritten spreadsheets and worries about lost passwords

  • Includes participant tutorials/training

  • Enables scheduling of reminders and notifications

For further information

Please contact Rachel Barrett