Instructions on managers’ transactions in FIN-FSA electronic services

An issuer’s managers and persons closely associated with them are obliged to notify the issuer and the Financial Supervisory Authority (FIN-FSA) of their transactions related to the said issuer’s shares, debt instruments, derivatives or other financial instruments (Market Abuse Regulation, MAR, Article 19).

More detailed information on matters related to the notification obligation can be found here.

Instructions for completing a new notification

You can find the notification form on the electronic transactions home page under ‘Services, ‘Manager’s transactions’.

First page (Basic information)

  • First, select the notification method you want. If you want to complete the notification form in a browser, select ‘Form’. If you wish, you can also send a preformed XML file.
  • In the ‘Notification details’ section, you can choose whether you are making your own notification or a notification on behalf of another, whether the entity subject to the notification obligation (obliged entity) is a natural or legal person and whether you are making a new notification or a change to a previous notification.
    • You must choose ‘Own notification’ if you yourself are the obliged entity. If you select own notification, the information of the person who is logged in to the service is automatically added to the obliged entity field. Remember, however, also to input the position of the obliged entity.
    • When ‘Notification on behalf of another’ is selected, it is possible to input the information of another person into the obliged entity field.
    • Natural or legal person is selected according to whether the obliged entity is a natural person or a closely associated entity.
    • New notification is always selected for the notification, unless the intention is to correct a notification sent previously. If ‘Amendment’ is selected, the case number of the notification to be corrected and the reason for the change will open on the form to be completed.
  • Provide the information of the obliged entity as well as the issuer’s information (name and LEI code).
  • If the obliged entity is a closely associated person, also state the name and position in the issuer of the person discharging managerial responsibilities.

Second page (Transaction information)

  • State the date and place of execution of the transaction.
  • State the nature of the transaction.
  • Provide instrument-related information.
  • Provide detailed information about the transaction.
    • First, select the price unit in order to enter the volume and the unit price.
    • If there are a number of executed items, you can also copy and attach separate transaction rows into the field reserved for them.
  • The form calculates the combined data automatically.
  • The second page should be added a number of times if the obliged entity has a number of transactions to be notified within the notification period and the transactions relate to different financial instruments of the issuer, different types of transactions, different trading venues or the transactions have been made on different dates. Each of the aforementioned items requires a separate page for transaction-specific information.

Third page (Summary)

  • On this page, you see the notification you have completed in both XML format and as a summary in stock exchange release format. You can copy this information from the page to be emailed to the issuer, who is required to disclose the notification information.

Fourth page (Submission)

  • From the page, you can download the notification you have made as an attachment in pdf format. Click the ‘Send’ button to send the notification to the FIN-FSA.

Making a change to a previous notification

  • If a transaction notification you previously submitted contains an error, you can make a correction by submitting an amendment notification. The easiest way to make an amendment notification is to:
    • In the electronic services top menu, select ‘Case folder’.
    • Select from the submitted items the manager’s transaction notification to be corrected.
    • Copy for yourself the case number of the notification to be corrected (which is in the format FISA XXX/02.05.10/2021).
    • Click the ‘Copy for template’ button.
    • On the first page of the form, change the notification type to ‘Amendment’. Two additional fields will open on the form, into which you can input the case number of the notification to be changed and the reason for the change.
    • After completing the additional fields, you can make the changes you wish to the items to be corrected on the form.
    • Finally, send the change notification in the same way as the first notification.