Domestic

Compliance with requirements relating to persons discharging managerial responsibilities under MAR

The Central Bank of Ireland (CBI) published a letter it sent to CEOs and company secretaries of certain equity issuers setting out the results of a targeted inspection of their compliance with requirements relating to persons discharging managerial responsibilities (PDMRs) under Article 19 of MAR. Although the inspection focused on selected issuers, the CBI expects all issuers to review the letter and assess if they need to remediate any deficiencies or introduce practices to comply with Article 19 of MAR and meet the CBI’s expectations. 

European

Council of the EU agrees key elements of the market integration and supervision package

On 9 October, the Council of the EU agreed its position on key elements of its negotiating position on the EU’s market integration and supervision (MISP) package, a key aspect of the EU's Savings and Investments Union initiative. The Council’s negotiating position must be finalised in line with the agreement in advance of formal adoption. Following this, negotiations between the Council and the European Parliament can begin after the European Parliament adopts its own negotiating position on the MISP package.  

Updated manual on pre-trade and post-trade transparency under MiFID II/MiFIR

On 15 October, the European Securities and Markets Authority (ESMA) published an updated version of its manual on pre-trade and post-trade transparency under MiFID II/MiFIR. Among the updates, is further guidance and clarification on the identification of over-the-counter (OTC) derivatives subject to transparency requirements and the identification of reference data for OTC derivatives for transparency purposes. With regard to the guidance on OTC identifying reference data, the updated manual should be considered a draft until the entry into force of the related technical standards.

Final draft guidelines on delayed disclosure of inside information under the Market Abuse Regulation

On 16 October, ESMA published its final report to update and streamline its guidelines on delayed disclosure of inside information under the Market Abuse Regulation (MAR). The guidelines are intended to help issuers with making decisions to delay disclosure by providing a non-exhaustive list of legitimate interests that could justify such delay. Following public consultation, ESMA added five legitimate interests to the non-exhaustive list of circumstances that could justify delaying disclosure of inside information. It also removed legitimate interests for delayed disclosure connected to protracted processes. The revised guidelines will apply from the date of their publication on ESMA’s website in all 24 official EU languages.

Commission Delegated Regulation on transparency for trading venues and investment firms, OTC derivatives and package orders

On 23 October, Commission Delegated Regulation (EU) 2026/1763 was published in the Official Journal of the EU. It amends key MiFIR regulatory technical standards in Delegated Regulation (EU) 2017/583 regarding transparency requirements for trading venues and investment firms in respect of derivatives. It also corrects Delegated Regulation (EU) 2017/587. The main provisions will apply from 1 March 2027. The application dates for certain provisions have been deferred to provide firms and market infrastructures with additional implementation time.

Date published: 12 November 2026

This publication provides an overview of certain legal and regulatory developments that may be of interest to certain entities. It does not purport to provide analysis of law or legal advice and is strictly for information purposes only.