MAR Corrected 2026: What Listed Companies and Intermediaries Must Review

Key data

Listed companies and financial intermediaries operating in European markets have a new document review obligation: the correction of the Regulation (EU) No 596/2014 on market abuse (MAR), published on 13 March 2026, corrects formal or material errors detected in the original text and requires that internal compliance procedures be updated to reflect the corrected version.

Although the correction does not alter the substantive regulatory framework of MAR, working with an outdated version of the regulation may compromise the validity of compliance procedures in the event of an inspection or enforcement proceeding. MAR is directly applicable in all Member States, which means it does not require national transposition and its compliance is immediately enforceable.

What does this regulation establish?

The Regulation (EU) No 596/2014 (MAR) is the European regulatory framework for preventing three illicit conducts in financial markets:

• Use of inside information: trading in markets with non-public information that could affect the price of a security.
• Unlawful disclosure of inside information: communicating inside information to third parties without legitimate justification.
• Market manipulation: conduct that artificially distorts the price or trading volume of financial instruments.

This correction—identified as CELEX:32014R0596R(14)—corrects formal or material errors detected in the text of MAR. It does not introduce new obligations or modify the enforcement regime, but ensures the correct application of the legal text. Companies must ensure that their compliance manuals, internal protocols and employee training are based on the corrected version.

Economic and operational impact

The direct impact of this correction is operational, not economic in terms of new fees or direct regulatory costs. However, the economic risk arising from failure to update procedures can be significant:

• Significant administrative sanctions for non-compliance with MAR, as established in the regulation itself.
• Criminal liability in those Member States that have criminalized market abuse conduct.
• Reputational risk for listed companies that are subject to investigation by national securities regulators.

The cost of updating internal procedures is marginal compared to the enforcement risk. The priority investment is time: reviewing that compliance documents cite and apply the corrected version of Regulation (EU) No 596/2014.

Who does it affect?

This correction affects all parties subject to the MAR Regulation throughout the European Union:

• Listed companies on regulated markets or multilateral trading facilities (MTFs) in the EU.
• Financial intermediaries: investment banks, brokers, fund managers, credit institutions with activity in securities markets.
• Persons with access to inside information: directors, board members, employees with access to non-public information about listed issuers.
• Compliance and legal departments of any entity subject to MAR, responsible for keeping internal procedures up to date.
• Legal advisors and consultants providing regulatory compliance services to financial entities or listed companies.

Practical example

A company listed on the Spanish continuous market has implemented an Internal Code of Conduct (RIC) that includes explicit references to Regulation (EU) No 596/2014 as the regulatory basis for its inside information protocol.

Following the publication of this correction on 13 March 2026, the compliance department must:

1. Verify whether any of the corrected articles are cited or developed in the RIC or in internal procedures.
2. Update references to the MAR text so that they point to the corrected version (CELEX:32014R0596R(14)).
3. Document the review carried out, so that there is evidence before the regulator that the company works with the current and correct text.

If the company does not carry out this update and is subject to an inspection, the regulator could question the robustness of its compliance procedures by detecting that they are based on a version of the regulation with uncorrected formal errors.

What should companies do now?

1. Download the corrected version of MAR from the official EUR-Lex repository and replace any previous version in compliance files.
2. Review internal procedures that cite or develop Regulation (EU) No 596/2014: Internal Code of Conduct, inside information protocols, insider lists and disclosure policies.
3. Update internal training so that employees with access to inside information work with the corrected text as a reference.
4. Document the review carried out with date and responsible party, creating a record that can be presented to the regulator if necessary.
5. Inform the Board of Directors or Audit Committee of the update carried out, especially in listed companies where corporate governance requires traceability of compliance actions.
6. Consult with specialized legal advisor if any of the corrected errors affects specific interpretations that the company has applied in the past, to assess whether there is exposure to enforcement risk.

Official source