Key Aspects
- Phased entry into force. The Listing Act is being implemented across four key dates: December 4, 2024, March 5, 2026, June 5, 2026, and December 5, 2026. The phased approach was designed to allow time for the European Commission to adopt delegated acts and for Member States to transpose the Directives, but in several areas the required Level 2 legislation and national transposition have not been completed on time, leaving issuers.
- Prospectus rules. Issuers must work from Level 1 and use draft delegated acts as non-binding guidance.
- MAR reforms. Reforms on inside information disclosure are live from June 5, 2026, but final guidelines will only come in Q4 2026. Pending ESMA's revised guidelines, issuers should apply the amended Level 1 rules with robust internal analysis and record-keeping, carefully documenting the assessment of when the "final event” occurs in a protracted process and the basis for any delayed-disclosure decision.
- Free float. Transposition of the 10% threshold is pending in Spain, requiring issuers to operate under the existing national framework.
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