Notification managers transactions MAR 19

The obligation to report transactions in financial instruments of the issuing institution itself (MAR 19) to the AFM applies to persons who:

  1. wholly or partly set day-to-day policy (executive directors for example);
  2. supervise the policy of the board and general company performance, including the related business activities (i.e. the members of the supervisory board);
  3. have a senior management position and hence the power to take decisions affecting future developments and business prospects, and who might regularly have knowledge concerning price-sensitive information;
  4. are closely linked to persons referred to in 1, 2 or 3.

€ 5000 per calendar year does not need to be reported. Once the total of the transactions in a calendar year exceeds € 5000, you must report these transactions.


While there are no specific charges for this service, issuers are required to pay an annual levy.


You can download the required notification form as a Word-document

The digitally completed form must be sent by email to And please also make use of this email address for all your questions regarding this notification in general.

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