Under the MAR (Article 18), all issuers must be able to identify any person working for them who has direct or indirect access to privileged information about the issuer and any third party who has access to privileged information as part of their professional relationship with the issuer, i.e., permanent insiders and occasional insiders.

All issuers listed on a regulated market have an obligation to draw up a list of all such persons, which must include at least:

• the identity of any person having access to inside information;
• the reason for including that person in the insider list;
• the date and time at which that person obtained access to inside information; and
• the date on which the insider list was drawn up.

Such information must be promptly updated where:

• there is a change in the reason for including a person already on the insider list;
• there is a new person with access to inside information who needs to be added to the insider list; and
• where a person ceases to have access to inside information.

Issuers or any person acting on their behalf or on their account must retain the insider list for a period of at least five years after it is drawn up or updated.

Such lists must be communicated to the AMF, using its online portal, on request.