What Is a PDMR? MAR Article 19 in Plain English

When a director of a European listed company buys or sells shares in that company, the deal becomes public within days. The rule behind this is Article 19 of the EU Market Abuse Regulation (MAR, Regulation (EU) No 596/2014), in force since 3 July 2016. The person it applies to is a PDMR: a person discharging managerial responsibilities.

Who is a PDMR

MAR Article 3(1)(25) defines two groups within an issuer:

• Members of the administrative, management or supervisory body. In practice: the board of directors, the management board and, in two-tier countries like Germany, the supervisory board.
• Senior executives who are not on those bodies but have regular access to inside information and the power to take managerial decisions affecting the company's future and business prospects. Both conditions apply, which is why a CFO usually qualifies and a head of investor relations usually does not.

The obligation also reaches persons closely associated with a PDMR: a spouse or partner, dependent children, relatives sharing the household for at least a year, and companies or trusts the PDMR manages or controls. A deal by a director's holding company is reported just like a deal by the director. We cover this in a separate post.

What must be reported

Every transaction on the PDMR's own account in the issuer's shares, debt instruments, derivatives or other linked instruments. That means more than market buys and sells: share awards, option exercises, pledges, gifts and inheritances are reportable too.

There is a de minimis threshold: nothing is due until the PDMR's transactions in a calendar year reach a set total, and then every transaction is reported. The EU Listing Act raised that threshold from €5,000 to €20,000, and national regulators may set it higher. Germany's BaFin moved to €50,000 on 1 January 2026.

How fast

The PDMR must notify both the issuer and the national regulator within three business days after the transaction. The issuer then publishes it. Some regulators run their own public register (BaFin, Sweden's Finansinspektionen, the Dutch AFM); elsewhere the filing appears as a regulatory announcement (the UK's National Storage Mechanism, Oslo Børs's Newsweb).

How fast is it in practice? We measured the gap between the transaction date and the publication date for 42,135 transaction lines published in the last twelve months, across 15 registers that state both dates:

Business days here are Monday to Friday; national holidays are not excluded. Late filings exist, and so do corrections filed weeks afterwards, which is why a filing's own date matters more than the day you saw it.

What a filing contains

MAR's implementing rules (Commission Implementing Regulation (EU) 2016/523) fix one template, used across the EU, the UK and Norway:

1. The person: name.
2. Reason for the notification: position or status, and whether this is an initial notification or an amendment.
3. The issuer: name and LEI.
4. The transaction: the instrument and its ISIN, the nature of the transaction (purchase, sale, award, exercise…), price(s) and volume(s), aggregated volume and weighted price, date, and place (a trading venue's MIC, or "outside a trading venue").

The template is shared, but the renderings are not. One register publishes a CSV, another an HTML table, a third a PDF or a press release in the local language. Germany's register shows the "volume" as an amount of money rather than a number of shares. The same field can mean different things in different places.

The closed period

Article 19(11) adds a trading ban: a PDMR may not deal during the 30 calendar days before the announcement of an interim or year-end report, with narrow exceptions. So insider dealing bunches up in the weeks after results are published.

Why the data is useful

A PDMR knows the business better than any outside analyst. When several of them put their own money in at the same time, it is worth knowing about. The difficulty is practical: the filings are spread over 17 national sources, each with its own format, language and history.

That is what Duceus does: it collects every register, maps each filing to one schema and serves it as an API. One call returns the latest PDMR deals in Sweden:

curl "https://api.duceusapi.com/transactions?country=SE&limit=5" \
  -H "Authorization: Bearer YOUR_API_KEY"

Each row carries the person's role at the time of the deal (person_role: CEO, CFO, board member, closely associated…), the filing's own wording (transaction_type_raw) next to a normalized transaction_type, and a link back to the original filing.

Summary

• A PDMR is a board member or a senior executive with access to inside information and real decision-making power.
• Their deals, and those of people closely associated with them, are reported within three business days once the yearly threshold is reached.
• Median time to publication across Europe is one business day; nearly nine in ten deals are public within three.
• The template is common; the registers are not.