Frequently asked questions

What is a PDMR?

A person discharging managerial responsibilities: a member of an issuer's administrative, management or supervisory body, or a senior executive with regular access to inside information and the power to take managerial decisions (MAR Article 3(1)(25)). Their own trades in the issuer's shares, debt and derivatives must be disclosed.

What is a PDMR

Who else has to report besides the managers?

Persons closely associated with a PDMR: a spouse or partner, dependent children, relatives who have shared the household for at least a year, and companies or trusts the PDMR manages, controls or benefits from. Duceus marks their transactions with is_closely_associated.

Closely associated persons

How fast must a manager's transaction be disclosed?

Within three business days of the transaction, to both the issuer and the national regulator (MAR Article 19(1)). The issuer must make it public within the same three business days. Some registers publish weeks later than that; Duceus stores the publication time it saw.

Is every transaction reported?

No. The obligation starts once a person's transactions in a calendar year reach a threshold, without netting buys against sells. The EU Listing Act set it at EUR 20,000, and a national regulator may set it higher or lower. Below the threshold nothing reaches the register.

What is the closed period?

The 30 calendar days before an interim or year-end report, during which a PDMR may not trade on their own account (MAR Article 19(11)), with narrow exemptions. Few filings dated inside that window is normal, not a gap in the data.

Is insider trading by managers legal?

Trading by managers is legal when it doesn't use inside information and is disclosed. Insider dealing, trading on inside information, is a market abuse offence. The filings in these registers are the legal, disclosed kind.

How do European PDMR filings differ from SEC Form 4?

Form 4 goes to one register, SEC EDGAR, in one structured format, within two business days. MAR Article 19 notifications go to about 30 national registers in a dozen languages and formats (web forms, PDFs, press releases), within three business days. The fields are similar: person, role, date, nature, volume and price. Duceus turns the European registers into one schema.

Are the United Kingdom and Switzerland covered?

Yes. The UK applies the same rules as UK MAR after Brexit; filings come through the FCA National Storage Mechanism. Switzerland is outside MAR: SIX Exchange Regulation publishes management transactions under its own rules and never names the manager, only the role, so these rows carry person_is_anonymized.

United Kingdom · Switzerland

Why can't I find older German filings at BaFin?

BaFin's Directors' Dealings database removes filings about 12 months after publication. Duceus archives each filing when it appears, so its German history reaches back further than the register itself.

BaFin Directors' Dealings

What happens when a filing is corrected or withdrawn?

When a register marks a filing as cancelled or replaced, or a later filing names the one it replaces, the old filing leaves every API response and webhook. It stays in the archive, so nothing is silently lost.

Where does the data come from?

From the national regulators and exchanges that receive the notifications: BaFin, AMF, FCA, CONSOB, Finansinspektionen, Newsweb and others. Every row in the API carries a link to the original filing.

Coverage by country

What is the difference between managers' transactions and major shareholdings?

Managers' transactions (MAR Article 19) are trades by the issuer's own managers, at any size above the yearly threshold. Major shareholding notifications (Transparency Directive) are filed by any holder whose voting rights cross a percentage threshold, usually funds and other companies. Duceus serves both: /transactions and /holdings.

Major shareholdings API · Major shareholdings vs insider dealings