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Published 23 junio 2016
Regardless of the result of today's referendum, the EU Market Abuse Regulation will come into force in the UK on 3 July 2016.
The new regime to prevent market abuse is being implemented through an EU Regulation and so will be directly effective as a matter of UK law, although some consequential changes are being made to the Listing Rules and the AIM Rules. However, in contrast to some similar situations in the past, the changes to domestic legislation and regulation are far more limited and the text of the EU Market Abuse Regulation itself (EU Regulation 596/2014), as well as the accompanying "Level 2" EU implementing rules, will be the primary source.
On and from 3 July 2016 new versions of the Listing Rules and the AIM Rules will apply. Not all of the accompanying EU "Level 2" implementing rules are yet available in final form, and indeed it appears, at least for several weeks after 3 July 2016, that will continue to be the case.
The changes brought about by the EU Market Abuse Regulation mean that companies listed in the UK - whether on the Main Market, AIM or ISDX - will almost certainly need to take some action now in order to update their policies and procedures. Whilst we understand that most, if not all, Main Market sponsors and AIM nominated advisers are in touch with their client companies about this, the areas affected will include:
As a result of the changes affecting UK listed companies, you will need to consider making changes to, amongst other things:
We expect to be in touch again as implementation of the regime, and of any associated "market practice", becomes clearer. However, if we can be of any assistance in the meantime, please contact either of the individuals below or your usual DAC Beachcroft contact.
London - Walbrook
+44 (0)20 7894 6045
+44 (0)20 7894 6308
David Manifould, Michelle Jones, Clive Garston, John Dunlop, Andrew Boulton
Nick Gibbon, Clive Garston, Bridget Salaman
David Manifould, Clive Garston, Andrew Boulton, Michelle Jones
Matt Spencer, Michael McCormack
Michael McCormack, Matt Spencer