Reporting transactions by persons discharging managerial responsibilities and persons closely associated with them
The AFM is currently developing a new form for reporting transactions by persons discharging managerial responsibilities (PDMRs) and persons closely associated with them. The AFM intends to introduce this form in the fourth quarter of 2026. From that moment onwards, it will no longer be possible to submit notifications by e-mail.
Important: The form and the associated personal context will only be visible once the form has been published.
To whom does this obligation apply?
The obligation to notify the AFM of transactions in shares, debt instruments, derivatives, or other financial instruments issued by the issuer concerned applies to:
• persons discharging managerial responsibilities (PDMRs);
• persons closely associated with them.
Transactions do not need to be reported until the total value of transactions reaches €20,000 within a calendar year. Once the cumulative value of transactions exceeds €20,000, you must report the transaction that causes the threshold to be exceeded, as well as all subsequent transactions during that calendar year.
How do you report a transaction?
To submit a notification, whether on your own behalf or on behalf of another natural person or legal entity, you need an account for the AFM Portal. Instructions for creating an account can be found on the AFM Portal landing page
Submitting a notification on your own behalf, on behalf of another natural person, or on behalf of a legal entity.
Submitting a notification on your own behalf
1. Log in to the AFM Portal.2. Navigate to Mandatory notifications.
3. Select your personal context in the purple navigation bar.
4. Via Notifications, go to the Reporting Transactions by Persons Discharging Managerial Responsibilities (Article 19 MAR) form.
Reporting on behalf of another natural person
To submit a notification on behalf of another natural person, you must first be authorized by that person.Authorising someone to report on your behalf
1. Log in to the AFM Portal.
2. Navigate to Mandatory notifications.
3. Select your personal context in the purple navigation bar.
4. Click MyAFM.
5. Go to Personal Context Authorisation and add the e-mail address of the person you wish to authorise. The authorised person must have an AFM Portal account.
Submitting a notification on behalf of another natural person
1. Log in to the AFM Portal.
2. Navigate to Mandatory notifications.
3. Select your personal context in the purple navigation bar.
4. Via Notifications, go to the Reporting Transactions by Persons Discharging Managerial Responsibilities (Article 19 MAR) form.
5. In the form, indicate that you are submitting the notification on behalf of another natural person.
Submitting a notification on behalf of a legal entity
1. Log in to the AFM Portal.2. Navigate to Mandatory notifications.
3. Select the relevant legal entity in the purple navigation bar.
4. Via Notifications, go to the Reporting Transactions by Persons Discharging Managerial Responsibilities (Article 19 MAR) form.
If the legal entity is not listed, you have not yet been authorised to submit notifications on its behalf. The organisation's authorisation administrator can grant you the ‘Capital markets Notifications’ authorisation. Instructions for granting authorisations can be found on the AFM Portal landing page.