MAR Delayed Disclosure Guidelines: Five New Grounds, Seven Deleted

ESMA published its final report on the MAR Guidelines on delay in the disclosure of inside information (ESMA74-268544963-1718) on 16 October 2026, completing the ESMA layer of the Listing Act’s rewrite of Article 17 of the Market Abuse Regulation. The revised MAR delayed disclosure guidelines delete seven of the eight legitimate interests in Guideline 1, keep the eighth with revised wording, to be applied restrictively, and add five new ones. Guideline 2, the list of situations in which a delay is likely to mislead the public, is deleted in full.

ESMA’s final revised guidelines remove the former examples concerning ongoing negotiations, pending Article 77 CRR authorisations and draft SREP decisions. The revised guidelines, though, become applicable only when ESMA publishes them in all 24 official EU languages. Since 5 June 2026, issuers have already had to apply the amended Article 17 MAR, under which qualifying intermediate steps in protracted processes are outside the ordinary disclosure obligation. The new grounds carry boundaries that ESMA spelled out paragraph by paragraph in its assessment.

Credit institutions that are MAR issuers lose the two bank-specific grounds added in the 2022 review, because Commission Delegated Regulation (EU) 2026/789 now lists the supervisory review and evaluation decision and the Article 77 CRR own-funds authorisation as protracted processes, each with its own moment of disclosure.

Related reading: CSSF Insider List Templates: Fields Dropped Under ITS 2026/1291

Key dates in the Listing Act overhaul of Article 17 MAR

The guidelines are the third layer of a sequence that started with the Listing Act and continued through a Commission delegated regulation. The dates below come from the final report, the Official Journal text of the delegated regulation and ESMA’s 16 October announcement.

Between 5 June and the final report, issuers worked under amended Level 1 text with guidelines written for the old one. The SMSG described this as a significant transitional guidance gap and recommended that ESMA issue interim guidance. The final report reproduces that advice in its own Annex III and contains no interim guidance.

What the Listing Act changed in Article 17 MAR

Three Level 1 changes drive the guideline review. Since 5 June 2026, Article 17(1) MAR no longer requires an issuer to disclose inside information about intermediate steps in a protracted process where those steps are connected with bringing about a particular event or set of circumstances. Only the final event or circumstance is disclosed, as soon as possible after it occurs. New Article 17(4a) takes those intermediate steps outside the delay regime altogether, and Article 17(7) still requires disclosure as soon as possible if their confidentiality is no longer ensured.

The second change rewrites one of the three delay conditions. The Listing Act replaced the old test in Article 17(4)(b), under which the delay had to be unlikely to mislead the public, with a comparison: the information the issuer intends to delay must not be in contrast with its latest public announcement or other type of communication on the same matter. The legitimate-interest condition in point (a) and the confidentiality condition in point (c) are unchanged.

The third change splits the mandate. Article 17(11) now asks ESMA only for a non-exhaustive, indicative list of legitimate interests under point (a). Article 17(12) empowers the Commission to list the final events in protracted processes, with the moment each is deemed to occur, and the situations in which delayed information is in contrast with the issuer’s latest communication. A further subparagraph of Article 17(4) lightens the load for issuers whose financial instruments are admitted to trading only on an SME growth market: they provide the written explanation of how the delay conditions were met only when the competent authority asks, and they need not keep a record of that explanation provided they can justify the decision on request.

Guideline 2 goes, and its replacement sits in the delegated regulation

That split is why Guideline 2 disappears. Its three examples, including the test of whether delayed information was materially different from a previous announcement, served the old misleading-the-public condition, and ESMA’s mandate no longer covers that condition. No consultation response opposed the deletion.

The replacement material sits in Delegated Regulation (EU) 2026/789. Annex II lists, on a non-exhaustive basis, eight situations in which inside information is in contrast with the latest announcement, running from a material change to forecasts, financial results or business objectives (profit warnings and earnings surprises are the examples given) to a material change in corporate governance. Annex III identifies seven types of public communication relevant to the contrast assessment. They include communications published by the issuer through media or its website; public interviews by formal representatives; publicly accessible pre-close calls, roadshows, webinars and podcasts organised or authorised by the issuer and involving a formal representative; public marketing campaigns; publicly accessible regulatory filings; publicly accessible communications at shareholder meetings; and any other communication to the public delivered by a formal issuer representative.

A delay checklist that still runs the Guideline 2 questions is testing against deleted text. A material change to previously announced forecasts appears on the Annex II list, which means a delay of that information fails the new point (b) before any legitimate interest is weighed.

The order of questions ESMA now expects

The final report sets a sequence for the disclosure committee. Once the issuer has established that inside information exists, the first question is whether it concerns an intermediate step in a protracted process, using Annex I of Delegated Regulation (EU) 2026/789 as support. If it does, no delay mechanism is needed, because only the final event or circumstance is subject to disclosure. If the information concerns a one-off event, or the final event of a protracted process, the delay mechanism is available provided every Article 17(4) condition is met (paragraphs 110 and 111 of the final report).

Annex I contains 35 entries in seven groups: business strategy; capital structure, dividends and interest payments; financial information; corporate governance; interventions by public authorities; credit institutions, insurance and reinsurance undertakings; and legal proceedings, sanctions and delisting. Each entry pairs a process with its final event and the moment of disclosure. A merger reaches its final event when the governing body approves the draft terms of merger. An agreement reaches it when a binding agreement or equivalent act is signed.

Three limits keep the list from doing more than it says. Recital 3 of the delegated regulation states that the list applies without prejudice to whether a particular protracted process gives rise to inside information at all. ESMA’s own list of legitimate interests is non-exhaustive, so an issuer may identify other interests through a case-by-case assessment (paragraph 105). And a listed interest creates no presumption that a delay is justified: ESMA restates that the legitimate interest is one of three conditions, that the contrast test and the confidentiality test must also be met, and that the listed interests are to be read restrictively, with disclosure due as soon as the circumstances justifying the delay come to an end (paragraphs 107 and 108).

The sequence changes the structure of the delay record. The protracted-process question now sits at the top, ahead of any legitimate-interest argument, because it decides whether the delay mechanism is engaged at all. Annex I of the delegated regulation supports that step where an entry fits, but its list is non-exhaustive; for an unlisted protracted process, Article 1 and recital 8 leave the identification of the final event and the disclosure moment to a case-by-case assessment, which the issuer should document with reasons available to the competent authority on request.

The revised Guideline 1 list at a glance

Annex I of the final report presents the revised guidelines as a marked-up version of the 2022 text. Read with ESMA’s assessment in Section 4 of the report, the list now runs from point (a) to point (f). The table gives each ground in short form with the boundary ESMA drew in its assessment; the guideline wording governs.

Seven grounds leave the list: negotiations whose outcome would be jeopardised by disclosure; decisions of the management body that need another corporate body’s approval to take effect; a product or invention whose disclosure would jeopardise intellectual property rights; a planned purchase or sale of a major holding; a previously announced transaction awaiting a conditional public-authority approval; and the two bank grounds covered further down. ESMA mapped the protracted processes in the delegated regulation against the old list and deleted each interest that related to a protracted process (paragraphs 20 and 21). The report does not publish that map line by line.

Relettering matters for anyone maintaining a disclosure policy. A policy, delay template or board paper that cites Guideline 1(b) meant financial viability under the 2016 and 2022 texts. Under the revised text, (b) is incident fact-finding, and the financial-distress ground appears as (d) in the marked-up annex.

Incidents and cyber-attacks: the delay ends at a rough estimate

Point (b) covers an issuer that needs to collect information on an exceptional event or circumstance, information that is not immediately available, so that market participants can assess the inside information correctly. The guideline’s example is gathering information on the effects of a major incident or cyber-attack, to give the public correct information and avoid the negative effects of a premature announcement.

ESMA used the consultation to pin down when incident information becomes inside information in the first place. Applying Article 7(2) MAR, the announcement of a severe incident may move prices on its own, regardless of a detailed damage assessment, so information about a severe incident can be inside information before its consequences are measured. Where nothing is yet known about the severity, the information may not be specific enough to qualify. The point (b) interest applies between those two stages: the information is precise and price-sensitive, and a better description of the damage is needed for a non-misleading announcement (paragraphs 55 to 58).

The delay is justified only for the time needed to collect enough information for a disclosure that does not mislead, and disclosure should take place as soon as a rough estimation of the damage is possible, ahead of any detailed analysis, with further information following later. ESMA drew two lines against respondents’ requests. Time to analyse the data collected, evaluate indirect impacts or plan remedial action falls outside the interest, because it would hold back market information to investors’ detriment. Respondents also asked for practical guidance on how long a delay could last in scenarios such as cyber-attacks; ESMA declined to set specific limits, such as 48 hours for cyber incidents, and leaves the length of the delay to a case-by-case assessment (paragraphs 50 and 59 to 63).

Incident reporting runs on its own timetable. Respondents asked ESMA to read the information-gathering window together with the notification deadlines under NIS 2, DORA and the GDPR. ESMA instead states that MAR disclosure obligations apply without prejudice to those notification duties (paragraph 62). For a listed financial entity, the DORA initial notification described in our guide to the ESAs’ DORA major incident reporting instructions and the MAR disclosure decision are two separate assessments drawing on overlapping facts.

ESMA also folded crisis management into point (b). Respondents had proposed a separate interest for operational, technological or security-related incidents; the final report treats those cases as covered by the new point (b) and adds no separate category (paragraph 95).

Authority orders and commercial opportunities

Point (a) covers an issuer that must comply with an order to keep inside information confidential, issued by a public authority of a Member State, the EU or a third country on the basis of law, a specific legal provision or powers otherwise attributed to that authority. ESMA’s report identifies two post-consultation amendments to the text: the powers otherwise attributed are explained as powers recognised by case law, and third-country authorities are named in the guideline itself (paragraphs 42 and 45). The guideline’s examples are an order not to disclose a tender award in public procurement and confidentiality required on grounds of public policy, public security or public health. The consultation paper’s illustration was a defence ministry requiring confidentiality about a defence contract on national security grounds (paragraph 34).

The guideline wording is tighter than ESMA’s own summaries. The 16 October news item and the report’s executive summary describe the issuer as requested not to disclose information by a public authority, while the guideline text speaks of an order with a legal basis. ESMA did not add separate criteria on proportionality and time limits, reasoning that a lawfully issued order already has to respect those principles under Member State constitutional traditions and EU law (paragraphs 39 to 41). Court orders and interim injunctions now fall under point (a) (paragraph 98).

On records, ESMA connects the order to the written explanation an issuer gives its competent authority under the second subparagraph of Article 17(4) MAR, and suggests that issuers keep the order documentation to support that explanation (paragraph 43).

Point (c) started as a public procurement example: an issuer that wins one tender while bids in a similar tender remain open could hand competitors its terms by announcing the first award. After consultation ESMA extended it to private competitive contexts and restated it as a test, covering sensitive commercial information whose disclosure may directly result in the loss of an identifiable and concrete business opportunity. The guideline now carries a second example: disclosure of an agreement or decision to enter a new market, or to launch a new product, which could let competitors adjust their strategy to the issuer’s detriment (paragraphs 75 to 79).

ESMA considers that most of the examples respondents offered, among them private negotiations, new product launches and financing arrangements, may qualify as protracted processes under the delegated regulation, so their intermediate steps are outside the disclosure obligation until completion. Point (c) is aimed at the final event, such as the signature of a strategic partnership agreement or the decision to launch. The interest ends with confidentiality: if a launch requires sharing sensitive information with distributors and the concrete steps no longer allow confidentiality to be maintained, the issuer discloses (paragraphs 78 and 80).

Financial distress: the one 2016 ground that survives

Almost every respondent to the first consultation question, 24 of 26, supported keeping the financial-viability interest, citing the risk that premature disclosure would undermine rescue measures and lead to the withdrawal of financing. ESMA kept it with new wording. The original phrase, financial viability in grave and imminent danger, uses terms generally found in insolvency law; it gives way to serious and imminent financial distress outside the scope of applicable insolvency law, where immediate disclosure would jeopardise the negotiations designed to restore the issuer’s capital and liquidity.

The interest applies restrictively to early-stage financial distress not covered by the delegated regulation, and only where the issuer is actively pursuing concrete measures to restore its liquidity and capital; the issuer verifies on an ongoing basis that the delay conditions remain met (paragraphs 28 and 29). Deteriorating financial performance sits outside it. Profit warnings remain subject to the general disclosure obligation in Article 17(1) (paragraph 30).

Annex I entries 25 and 26 of the delegated regulation mark the other boundary. For pre-insolvency or restructuring proceedings supervised by a court, the final event is the governing body’s decision to file; where no court supervises the process, it is the signature of an agreement with creditors or another pre-insolvency arrangement. For insolvency, the trigger is the governing body’s decision to file. Point (d) covers the stretch before those processes begin, the informal rescue phase that ESMA described as preceding formal proceedings.

Appointments and group companies: the two late additions

Two grounds were absent from the consultation paper. Point (e) covers the appointment of a governing body member, a manager or another person in a key position who has not yet told their current employer of their intention to terminate the employment contract, where disclosure could jeopardise the effectiveness of the governing body’s decision. Part of ESMA’s reasoning concerns accuracy: where taking up office depends on ending a prior contract, an early announcement could mislead the market if the appointment falls through or happens later than expected (paragraph 86).

The interest attaches to one moment. Preliminary discussions about an appointment are negotiations and are not subject to disclosure; the delay applies only to the appointment decision formally taken by the governing body, and only for the period strictly necessary to secure it (paragraph 87). That fits Annex I entry 13 of the delegated regulation, which makes the decision to appoint or remove a governing body member or key manager the final event. Resignations did not make the list. ESMA rejected a proposed interest for holding back news of a key executive’s resignation until a successor is found, because the delay would conceal a governance vacuum from investors (paragraphs 88 and 89).

Point (f) addresses groups in which more than one company is subject to MAR disclosure. Where another group company has delayed disclosure under Article 17(4), the issuer may have a legitimate interest in delaying the same information for the same period, provided close economic and operational links mean immediate disclosure would cause it direct prejudice and undermine the other company’s delay. ESMA’s examples are a holding company with no operating business of its own, and a confidentiality order addressed to the subsidiary but not to the parent (paragraphs 90 and 91). The report also points to the pending preliminary reference in Case C-53/26, submitted by the German Bundesgerichtshof, as an example of a holding company affected by inside information about a subsidiary’s business.

Two limits come with point (f). Recognising the interest creates no automatic group-wide interest under which one entity’s delay justifies delays across the group (paragraph 92). Article 10 MAR on unlawful disclosure still governs the flow inside the group, so a subsidiary’s inside information reaches parent-company staff only in the normal exercise of their employment, profession or duties (paragraph 93).

Pre-announcement coordination got no ground of its own. Respondents asked for a delay to coordinate with third parties, authorities or employees before an announcement; ESMA treats that coordination as part of disclosing properly and limits the delay mechanism to situations where the issuer has no other option to avoid damage to its legitimate interests (paragraph 94).

Banks: SREP and own-funds approvals move to the delegated regulation

The 2022 review added two grounds for institutions. One covered a decision to redeem, reduce, repurchase, repay or call own funds instruments, or to reduce, distribute or reclassify the related share premium accounts, taken but not yet authorised by the competent authority under Article 77 CRR. The other covered a draft SREP decision or preliminary information about it, on the reasoning that a premature announcement would cut across the SREP procedure and the institution’s right to be heard. Both are deleted.

Their replacement is section F of Annex I to Delegated Regulation (EU) 2026/789. Entry 27 treats the supervisory review and evaluation under Article 97 of the CRD as a protracted process whose final event is the competent authority’s formal decision. Disclosure is due as soon as possible after the credit institution has received the final SREP decision, even where the issuer and the authority previously exchanged preliminary information or draft decisions that may on their own amount to inside information. Entry 28 does the same for a reduction of own funds under Article 77 CRR: disclosure follows as soon as possible after the institution is notified that the reduction has been authorised, with the same wording on earlier exchanges. Section F also covers preparation for resolution action and national insolvency proceedings.

Draft SREP decisions stay out of the market under the new model through a different route. The draft is an intermediate step in a protracted process, so Article 17(1) does not require its disclosure, Article 17(4a) keeps it outside the delay requirements, and Article 17(7) still requires disclosure if its confidentiality is lost. A delay of a final SREP decision under Article 17(4) requires a legitimate interest and compliance with the contrast and confidentiality conditions; the revised Guideline 1 no longer identifies a SREP-specific legitimate interest.

Separately, Article 17(5) MAR provides an exceptional delay route for an issuer that is a credit institution, a financial institution or the parent undertaking of such an institution. The issuer must establish that disclosure risks undermining the financial stability of both the issuer and the financial system, that delay is in the public interest and that confidentiality can be ensured. Under Article 17(6) MAR, the issuer must notify the competent authority of its intention to delay and provide evidence supporting those conditions, and the delay requires the competent authority’s consent under Article 17(5); if consent is refused, Article 17(6) requires the issuer to disclose the inside information immediately. Our explainer on the revised EBA SREP guidelines covers the supervisory side of the same cycle.

The Pillar 2 guidance survives the review. Institutions subject to prudential supervision under the CRD are still told to verify whether draft or final P2R is non-public, directly related to them and precise. P2R is described as highly likely to be price-sensitive, with price sensitivity not excluded even where current capital exceeds P2R, and except in a very limited number of cases after a thorough assessment it is expected to be inside information. P2G may also be price-sensitive, and the guidelines give two examples of situations where it is expected to be: the gap between P2G and the institution’s capital is not minor and likely to require a major reaction such as a capital increase, or P2G is out of line with market expectations. These paragraphs move up in the numbering once Guideline 2 is deleted.

One sequencing question remains open. A bank buy-back of its own shares can read as the share buy-back entry in section B of Annex I, whose final event is the governing body’s final decision, and as entry 28, whose final event is the authority’s authorisation of the own-funds reduction. The deleted Article 77 ground used to cover precisely the window between the board decision and the authorisation, and entries 7 and 28 do not say which governs when both describe the same transaction. Our explainer on prior permission for own funds reductions sets out the authorisation process that frames that window.

Applying the MAR delayed disclosure guidelines in the delay file

Under Article 16(3) of the ESMA Regulation, competent authorities and financial market participants must make every effort to comply with the guidelines. Within two months of publication in all official languages, competent authorities notify ESMA whether they comply, intend to comply or do not comply, giving reasons for any non-compliance on a template available on ESMA’s website. Issuers are not required to report whether they comply.

The scope section names two addressees: competent authorities designated under Article 22 MAR, and issuers. An issuer for this purpose is a legal entity within Article 3(1)(21) MAR that is subject to the disclosure obligation in Article 17(1). The definitions section extends public authority to authorities of a Member State, the EU or a third country, which is the basis for a foreign order counting under point (a).

ESMA’s cost-benefit analysis in Annex II of the final report records no compliance cost. The amendments introduce no new procedural requirements and clarify the existing framework, and ESMA states that familiarisation with the new disclosure regime is not a compliance cost attributable to the guidelines. The change therefore falls on documents a compliance function already keeps: the delay decision template, the list of grounds in the disclosure policy, the incident playbook and the group disclosure protocol.

Frequently Asked Questions

A delay opened before 5 June 2026 under the old negotiations ground is still running. Does the revised text change it?

The final report contains no transitional provision for delays already in progress. The Level 1 position has applied since 5 June 2026: if the information concerns an intermediate step in a protracted process, Article 17(1) no longer requires its disclosure and the delay mechanism is not needed; if it concerns a final event or a one-off event, the delay holds only while all three Article 17(4) conditions are met, including the new contrast test. The report does not address how an earlier delay record is closed out with the competent authority.

Our agreement with the counterparty contains a confidentiality clause that prohibits any announcement. Is that a legitimate interest for delay?

ESMA considered the point and rejected it. Recognising contractual confidentiality clauses as a standalone ground could invite misuse, because the issuer and its counterparty insert such clauses voluntarily, which would leave the issuer excessive discretion over whether to disclose on time (paragraph 97). A delay in that situation would need to rest on another interest, such as point (c), together with the other Article 17(4) conditions.

The delayed information lost its price sensitivity before we disclosed it. Is a notification to the competent authority still due?

ESMA’s MAR Q&A 5.2 (ESMA_QA_1721) covers this. Once delayed information loses its price sensitivity it is no longer inside information, so the issuer is obliged neither to disclose it nor to inform the competent authority of the delay. The insider list and the records of the delay are still required, because the information was inside information for a period. The Q&A dates from 2017 and predates the Listing Act.

The authority’s confidentiality order has no expiry date. When does the delay end?

Respondents asked exactly this. ESMA’s answer rests on administrative law: under proportionality and necessity, an authority’s powers should not outlast the reason for them, a principle that can appear as sunset clauses, periodic review or renewal requirements. The delay lasts only for the time the order requires confidentiality, and the issuer has to disclose as soon as the order expires (paragraph 44).

Does notifying a major ICT incident to our supervisor under DORA break the confidentiality condition for a MAR delay?

The final report addresses the point only indirectly, by recalling that the authorities receiving incident notifications under NIS 2, DORA and the GDPR are legally bound to keep them confidential under the sectoral legislation (paragraph 62). The Article 17(4)(c) condition is still assessed on the facts, and a leak outside the notification channel triggers the Article 17(7) duty to disclose as soon as possible.

Our shares trade on an SME growth market and our bonds on a regulated market. Do we benefit from the lighter written-explanation regime?

The final report describes the relief as applying to issuers whose financial instruments are admitted to trading only on an SME growth market (paragraph 7). An issuer with instruments also admitted to a regulated market falls outside that description, so the standard written-explanation requirement in Article 17(4) applies to it.

Related Articles

• CSSF Insider List Templates: Fields Dropped Under ITS 2026/1291: the Listing Act’s companion change to MAR insider lists, including the separate SME growth market format.
• EBA Revised SREP Guidelines: What EU Banks Must Review in ICAAP, ILAAP and Pillar 2 Capital: the supervisory review cycle whose final decision now sets the MAR disclosure moment for listed banks.
• MREL Prior Permission for Own Funds Reduction: how the prior permission regime applies to reducing own funds and MREL instruments.
• DORA Major Incident Reporting: The ESAs’ Filing Instructions: the incident notification workflow that runs alongside a MAR incident assessment.
• ESMA Prospectus Disclosure Guidelines: The 9 November 2026 Deadline: ESMA’s consultation on updated Prospectus Regulation disclosure guidelines and related Q&As.

Key Takeaways

• Delay decision template: first determine whether the information concerns an intermediate step, a final event in a protracted process or a one-off event. Use Annex I of Delegated Regulation (EU) 2026/789 where applicable, recognising that its list is non-exhaustive. For an unlisted protracted process, document the case-by-case identification of the final event and disclosure moment, with supporting reasons available to the competent authority on request.
• Disclosure policy: re-check every cross-reference to Guideline 1 letters against the new (a) to (f) sequence before the guidelines apply.
• Contrast check: apply the Article 17(4)(b) MAR test against the issuer’s latest public announcement or other communication on the same matter. Use the eight Annex II situations as non-exhaustive examples and review the seven Annex III communication categories. Where the latest communication alone does not allow a clear conclusion, also consider earlier announcements or communications, as specified in recital 9 of Delegated Regulation (EU) 2026/789.
• Incident playbook: add a MAR disclosure checkpoint to incident response, separate from the DORA, NIS 2 and GDPR notification steps.
• Listed banks: time SREP and Article 77 disclosures from receipt of the final SREP decision (entry 27) and notice of the authorisation (entry 28), and settle how a share buy-back is sequenced before the next programme.
• Authority orders: keep the order, its legal basis and its expiry on file to support the Article 17(4) written explanation.
• Group issuers: document which entity delays, on which ground, and the Article 10 basis for any sharing of the information between subsidiary and parent.

Sources and References

• ESMA, Final Report: MAR Guidelines on delay in the disclosure of inside information, ESMA74-268544963-1718 (16 October 2026): ESMA final report (PDF)
• ESMA, “ESMA finalises the review of guidelines on the delay in disclosure of inside information” (16 October 2026): ESMA news item
• ESMA, Consultation Paper on MAR Guidelines on Delayed Disclosure, ESMA74-268544963-1567 (February 2026): ESMA consultation paper (PDF)
• ESMA, MAR Guidelines: Delay in the disclosure of inside information, ESMA/2016/1478 (20 October 2016): ESMA 2016 guidelines (PDF)
• ESMA, Final Report on the Technical advice concerning MAR and MiFID II SME GM, ESMA74-1103241886-1086 (May 2025): ESMA technical advice (PDF)
• Commission Delegated Regulation (EU) 2026/789 of 8 April 2026 supplementing Regulation (EU) No 596/2014 as regards disclosure of inside information in protracted processes and delay of disclosure (OJ L, 16 July 2026): EUR-Lex
• Regulation (EU) 2024/2809 (Listing Act) amending Regulations (EU) 2017/1129, (EU) No 596/2014 and (EU) No 600/2014: EUR-Lex
• Regulation (EU) No 596/2014 (Market Abuse Regulation), Articles 7, 10 and 17: EUR-Lex
• Regulation (EU) No 1095/2010 (ESMA Regulation), Article 16: EUR-Lex
• Directive 2013/36/EU (CRD), Article 97: EUR-Lex
• Regulation (EU) No 575/2013 (CRR), Article 77: EUR-Lex
• Regulation (EU) 2022/2554 (DORA): EUR-Lex
• Directive (EU) 2022/2555 (NIS 2 Directive): EUR-Lex
• Regulation (EU) 2016/679 (GDPR): EUR-Lex
• ESMA, MAR Q&A 5.2, ESMA_QA_1721 (2017): ESMA Q&A

Next checkpoint: the translated MAR guidelines

The revised guidelines apply on the date ESMA publishes them in all 24 official EU languages, and the 16 October release does not give that date. The Level 1 sequence behind them, with intermediate steps outside Article 17(1) and the contrast test in point (b), has applied since 5 June 2026, so the delay decision template can move to the protracted-process-first order before the translations arrive.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.