Set up an insider list to delay disclosure of inside information

Create a new insider list

  1. To open a new insider list, click the new list button.

  2. Start filling in all the fields under basic information and add a list title. The list title will be visible for the insiders you add to the list.

  3. Under inside information, specify what the information is concerning in further detail. For example, 'Purchase of competitor X'. Short description of the project. This will not be visible to the insiders. Only visible to the admin and a part of the documentation of the insider list.

  4.  The list created field is auto-populated with the current date and time. Make sure that the correct date and time for when the information was identified is entered. 

  5. Add the person who is responsible for the delayed disclosure; this is who is responsible as set out in article 4.1(b) of implementing regulation 2016/1055.

  6. Assign an admin group that will access and manage the list.

  7.  Set your reminder frequency. The default is one day, which means that the insiders will receive daily reminders until they complete their form. This can be customised. 

  8. Add additional notes if needed.


  9. Keep the public disclosure is not being delayed box unchecked.

  10. Fill in all fields under determination whether public disclosure can be delayed and answer all the required questions. If your answer is not compliant with MAR’s requirements, the system will tell you that you’re not allowed to delay the disclosure. 

  11. Once the relevant sections are complete, click the create list button.

Add insiders

Now that your list is created, you can start adding insiders to the list.

  1. Press add person.
  2. Enter the email address(es) of the person(s) you want to add. You can also add a contact group name. Contact groups can be created under the contacts tab.
  3. Enter the date and time when the insider(s) received the information.
  4. Choose which email to send to the added person(s): 
    1. Send email with notice of obligations and link to form (to collect confirmation and personal details). 
    2. Include a request that the insider must keep a sub-list. 
    3. Send custom email instead of using the standard template. This will allow you to edit the email before sending it.
    4. Uncheck all boxes to avoid triggering an email to the insider.

Proceed to Add member(s) to list.

Insider status

Under Status in the list view, you can see if the status is complete or incomplete, which shows whether the person has or hasn’t filled in the form and confirmed that they’ve received and understood the information in the email. 

Edit added persons

If you click on edit next to a person’s email address in the list, you’ll access the person's form with their personal information. Here, you may make changes, if needed.

As an administrator, you are able to fill in the form for the person by entering all fields. Before saving, you may choose if you want to save the person as complete or incomplete
Remember that if you fill this out before the person has responded you need to separately notify the person of its obligation and collect a confirmation that it has received and understood.

At the bottom of the form, you can find the email history connected to this person. You can find which email has been sent out as well as the date and time stamp.  

Send reminders

  1. If you want to send a manual reminder or a customised email to all persons on the list, use the send reminders button. 


    Use the default email template as content for your reminder or edit the template how you wish.  
  2. To send a reminder to just one person, click edit next to their name in the list.

    Click send reminder to send the message to just that individual.

Delete person

  1. Click delete next to the person's name in the list.
  2. A dialog box will ask you to confirm the deletion. Click proceed to delete the person.

List settings

  1. To access the list settings, click the settings button.

    From the settings page, you can change the title of the list, change the admin group managing the list, set the frequency at which you send reminders to members who are yet to confirm their details and add notes.
    Under the settings, you may also attach files to the list that will be visible to the admins.

Audit trail

  1. To access the audit trail, click the history button.

Here, you can find a full audit trail of changes and events made in the list, when they happened, and who actioned them. 

    Export list

    1. To export the list, click the export button.


    2. Using the checkboxes, you can choose the content of your export. You also have the option to download the list as an Excel file. By default, it will be exported in pdf format.
    3. Use the dropdown menu to choose the language in which you want the file to be.
    4. Choose the date you want the export to reflect using the calendar function.
    5. Click proceed to begin the download.