What this chapter covers
The Market Abuse Regulation (EU) No 596/2014, applying since 3 July 2016, sets one rulebook across the EU for insider dealing, unlawful disclosure of inside information and market manipulation. In Cyprus, Law 102(I)/2016 gives CySEC its powers and fines under the Regulation, and Law 136(I)/2016 sets the criminal penalties. The first notes explain what inside information is, who counts as an insider, which behaviour stays lawful and how market soundings work.
The middle notes cover what issuers must do: publish inside information or delay it under strict conditions, keep insider lists and make their managers' own dealings public. The last group deals with market manipulation and suspicious transaction reports, investment recommendations and the sanctions CySEC and the courts can impose.
The EU Listing Act changed several of these rules from December 2024 and June 2026: a higher threshold for managers' transactions, an optional safe harbour for market soundings, a new test for delaying disclosure and, for protracted processes, disclosure of the final event only. Each note teaches what the exam tests and says what applies today.
The 10 topics
Each note starts with a short answer and a table of the facts to remember.
Inside information and insider dealing
- What is inside information under the Market Abuse Regulation?The four features of inside information, how precision and significance are judged, and the special cases of pending orders and commodity derivatives.7 min
- What is insider dealing, and who counts as an insider?Trading, changing orders and recommending on inside information, who counts as an insider, and when information has been made public.7 min
- What does MAR prohibit, and when is holding or sharing inside information lawful?The three prohibitions of Article 14, the legitimate behaviour that is not insider dealing, and when sharing inside information is lawful.6 min
- What is a market sounding, and how can inside information be shared lawfully in one?Who may sound out investors, the written assessment, the optional safe harbour since December 2024, cleansing and record keeping.5 years7 min
Issuers' disclosure duties
- When and how must an issuer disclose inside information, and when may it delay?Publishing inside information, the three conditions for delay, the notice to CySEC, protracted processes and leaks.5 years8 min
- What must an insider list contain, and who must keep it?Who keeps insider lists, what each entry records, updates and retention, and the lighter regime for SME growth market issuers.5 years7 min
- When must managers and their close associates report their dealings, and when may they not trade?Who counts as a manager or close associate, the notification threshold and deadlines, publication and the closed period.€20,0003 business days30 days8 min
Manipulation, recommendations and sanctions
- What is market manipulation, and how is it detected and reported?False signals, artificial prices, rumours and benchmarks, suspicious transaction and order reports, and accepted market practices.8 min
- What rules apply to investment recommendations, statistics and information given to the media?Objective presentation and disclosure of interests, statistics from public bodies, and how journalists are treated.6 min
- What sanctions apply to market abuse in the EU and in Cyprus?The measures and fines MAR requires, CySEC's fines under Law 102(I)/2016 and the criminal penalties under Law 136(I)/2016.€5m / €15m5 years8 min
The numbers to know
Every figure in this chapter, with the note that explains it.
| Figure | What it is | Note |
|---|---|---|
| €20,000 | Total of a manager's own dealings in a calendar year, added without netting, from which they must be notified (since 4 December 2024; Cyprus applies this figure) | Topic 7: When must managers and their close associates report their dealings, and when may they not trade? |
| 3 business days | Deadline for managers and their close associates to notify a transaction to the issuer and the regulator | Topic 7: When must managers and their close associates report their dealings, and when may they not trade? |
| 2 business days | Time the issuer has to publish a manager's transaction after receiving the notification | Topic 7: When must managers and their close associates report their dealings, and when may they not trade? |
| 30 calendar days | Closed period before an interim or year-end report during which managers may not deal, save in permitted cases | Topic 7: When must managers and their close associates report their dealings, and when may they not trade? |
| 5 years | Minimum period for keeping insider lists and market-sounding records, and for keeping inside information on the issuer's website | Topic 6: What must an insider list contain, and who must keep it? |
| €5m · €15m | CySEC's fixed maximum fines for an individual and for a company for insider dealing, unlawful disclosure or market manipulation; a fine of up to three times the profit gained or loss avoided is also possible | Topic 10: What sanctions apply to market abuse in the EU and in Cyprus? |