Germany's Federal Financial Supervisory Authority raises directors’ dealings reporting threshold to EUR 50,000 from 1 January 2026

Germany's Federal Financial Supervisory Authority has issued a general administrative order increasing the calendar-year threshold for reporting managers’ own-account transactions under Article 19 of the Market Abuse Regulation from EUR 20,000 to EUR 50,000. The change applies to transactions by persons discharging managerial responsibilities and closely associated persons in an issuer’s shares or debt, related derivatives or other related financial instruments, and to transactions in emissions allowances and related auction products or derivatives. The measure follows amendments to Article 19 introduced by the EU Listing Act, which set the EU-wide threshold at EUR 20,000 and allowed national authorities to lower it to EUR 10,000 or raise it to EUR 50,000 subject to notification to the European Securities and Markets Authority. BaFin’s decision is supported by an analysis of reporting data for 2021 to 2024, where median annual totals per reporting person were consistently above EUR 100,000; based on those data, BaFin expects the higher threshold to reduce the number of notifications by up to one third while still capturing a substantial share of transactions and reducing compliance burden, particularly for smaller and medium-sized issuers. The order revokes BaFin’s 2019 general order that had set the threshold at EUR 20,000 and includes a reservation allowing BaFin to revoke the new order prospectively. It is deemed notified the day after its public announcement, and an objection can be filed within one month of notification.