The EU Market Abuse Regulation (MAR), which contains new rules about dealing in shares by directors and “persons discharging managerial responsibilities” (PDMRs), will come into force on 3 July 2016. Unlike the current rules, which are different for companies on the full list and those on AIM, the MAR will apply to all quoted companies.
So how will MAR affect share plans?
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- review the rules of their share plans to see if amendments to references to the Model Code or the AIM dealing rules need to be made;
- re-visit the relative timing of vesting of awards where tax is to be funded by the immediate sale of some of the shares by the participant;
- consider delaying vesting if it will fall within the new definition of close period; and
- update their guidance for the company and relevant share scheme participants about insider dealing.