1) Beneficial ownership: Implementing Regulation defining the formats for communications to the central register published in the OJEU

On 22 October 2026, Implementing Regulation (EU) 2026/2354 (the “Regulation”) was published in the Official Journal of the European Union, defining the common formats for the transmission of beneficial ownership information to the central registers of the Member States, in implementation of Directive (EU) 2024/1640 (the so-called Sixth Anti-Money Laundering Directive).

The Regulation aims to ensure greater uniformity, completeness and interoperability of the information, by introducing minimum requirements and standardized methods of communication. In particular, it provides for the recording of data relating to each legal entity and beneficial owner and, in the case of complex corporate structures, the transmission of organizational charts representing ownership and control relationships. Alternative methods of transmitting data and derogations for information already available in other registers are also provided for, in order to reduce administrative burdens.

The Regulation will apply from 10 July 2027.

2) ESMA: revised MAR Guidelines on delay in the disclosure of inside information published

On 16 October 2026, the European Securities and Markets Authority (“ESMA”) published the updated version of the Guidelines on the delay in the disclosure of inside information to the public, under Regulation (EU) 2014/596 on market abuse (the so-called Market Abuse Regulation – MAR), with the aim of simplifying the regulatory framework and providing issuers with greater certainty.

The Guidelines identify the circumstances in which issuers may legitimately delay the disclosure of inside information in order to protect their interests. In particular, ESMA has introduced five additional legitimate interests justifying such delay:

• requests for confidentiality from public authorities;
• the need to obtain additional information in order to enable a correct assessment of the inside information by market participants;
• the risk of jeopardizing business opportunities as a result of the disclosure of commercially sensitive information;
• the risk of jeopardizing the appointment of members of the management body or of senior managers; and
• disclosure of information relating to companies of the same group, where the disclosure may cause direct prejudice to the issuer and undermine the effectiveness of the delay applied by another company

In addition, from June 2026, issuers will no longer be required to disclose immediately inside information relating to protracted processes before their completion. Consequently, ESMA has removed from the current guidelines the legitimate interests that justified delaying disclosure in relation to such processes.

The new Guidelines will apply from the date of their publication on the ESMA website in the 24 official languages of the European Union.