UK FCA Inside Info Disclosure

On Jun. 11, FCA proposed technical note on disclosure delay.

FCA Consultation

  • Held discussion with a range of stakeholders on issue of identifying and handling
    inside information during the preparation of the entity's periodic financial reports.
  • Proposed update note UKLA/TN/506.1 on periodic reports, and inside information.


  • Follow ESMA guide on delayed disclosure of inside information, per MAR Art. 17(4).
  • Guidelines give example of legitimate interests that are likely to be prejudiced by
    immediate disclosure of information, situation where delay likely to mislead public.
  • Examples are non-exhaustive, and a national regulator can give further guidance.

FCA Example

  • In proposal, FCA gave example of legitimate interest of an issuer which may exist.
  • This includes when issuer is in the process of preparing a periodic financial report.
  • FCA does not think issuers should assume that this interest will always be present.
  • By its nature, this legitimate interest is limited to the situations in which the inside information emerges as part of the process of preparing a periodic financial report.
  • Issuers should assess the existence or otherwise, of legitimate interest which may
    be prejudiced by the immediate disclosure of inside information on ongoing basis.
  • Issuers who choose to delay disclosure of information do so on own responsibility.


  • Comments are to be sent, by Jul. 23, 2018, before the guidance is finalized.