PDMR vs. closely associated person
Why a CEO's wife buying their stock is still public record.
MAR Article 19 doesn't just cover the PDMR personally. It covers a defined circle of "closely associated" people and legal entities around them. When they trade, it's disclosed under the PDMR's name.
Who's closely associated?
- Spouse / civil partner of the PDMR
- Dependent children (under 18, or legally dependent adults)
- Other relatives who have shared a household for at least 12 months at the date of the transaction
- Any legal entity (company, trust, foundation) where the PDMR or one of the above is a director or controlling shareholder
Why this matters: the biggest insider transactions are often not in the PDMR's own name. They're in the name of a family holding company, an investment vehicle, or a trust. BASF, Mercedes-Benz, Henkel, Hermès — huge swaths of European corporate ownership sit in these structures.
How we handle it: we treat "closely associated" transactions as equivalent to direct PDMR transactions in the filings table. On individual insider profiles we show the role exactly as filed ("Vorstand", "Aufsichtsrat", "in enger Beziehung") so you can see the nature of the link.
Signal quality: a family holding company buying €10M of their own stock is sometimes a stronger signal than the CEO buying €100k, because the holding represents long-term family wealth, not a one-off opportunistic bet. Worth weighing.