The Norwegian Financial Supervisory Authority has issued a decision imposing an administrative penalty of NOK 20,000 for a breach of the notification duty under Article 19 of the Market Abuse Regulation and Section 3-1 of the Securities Trading Act. The case concerned the sale of 8,200 VAR shares on March 20, 2026, by an alternate board member for an employee representative, whom the authority treated as a primary insider and a member of the issuer's administrative, management or supervisory body for these purposes. It found that the transaction, worth NOK 392,223, exceeded the EUR 5,000 annual threshold and should therefore have been notified in full. The transaction was reported to the authority and the market on March 30, 2026, rather than immediately after execution and no later than three days after the trade. In rejecting the individual's argument that the delay was due to lack of awareness of the rules, the authority pointed to written notifications from VAR about the MAR Article 19 obligations and completion of internal training programs. In setting the penalty, it placed particular weight on the size of the trade and the length of the delay, noting that the market was deprived of timely information for 10 days, including five trading days. It gave little mitigating weight to the person's limited trading experience and lack of participation in board meetings, but said the penalty amount was nevertheless reduced to NOK 20,000 following an overall assessment.
Norwegian Finanstilsynet2026-07-07
Norwegian Financial Supervisory Authority imposes NOK 20000 penalty for delayed disclosure of VAR share sale under MAR Article 19
The Norwegian Financial Supervisory Authority fined a VAR primary insider NOK 20,000 for failing to disclose a share sale in line with MAR Article 19. The 8,200-share transaction, worth NOK 392,223, was reported 10 days after the trade, and the authority found that the individual had previously been informed of the disclosure obligations.