Germany's Federal Financial Supervisory Authority (BaFin) has opened a hearing on a planned general administrative act to increase the Market Abuse Regulation (Regulation (EU) No 596/2014) threshold for reporting managers’ own-account transactions (directors’ dealings) from EUR 20,000 to EUR 50,000 per calendar year, with application intended from 1 January 2026. The proposed threshold would apply to transactions by persons discharging managerial responsibilities and closely associated persons in an issuer’s shares or debt instruments and related derivatives or other linked financial instruments, as well as transactions in emission allowances and related auction products and derivatives. BaFin’s analysis of reporting data for 2021 to 2024 found median annual aggregated volumes per reporting person consistently above EUR 100,000, and estimates the higher threshold could reduce notifications by up to one third; it also proposes to revoke its 24 October 2019 general administrative act that set the previous EUR 20,000 threshold. Comments are due by 17 November 2025, after which BaFin will decide whether to issue the measure; the draft provides for the new threshold and the revocation of the 2019 act to take effect on 1 January 2026.
BaFin 2025-10-27
Germany's Federal Financial Supervisory Authority consults on raising directors’ dealings reporting threshold to EUR 50,000
Germany's Federal Financial Supervisory Authority (BaFin) may raise the Market Abuse Regulation threshold for reporting managers’ own-account transactions from EUR 20,000 to EUR 50,000 per year, effective 1 January 2026. This change aims to reduce notifications by up to one third, as data shows median annual volumes per reporting person exceed EUR 100,000. BaFin also plans to revoke its 2019 administrative act that set the previous threshold.