US vs Europe Insider Trading: Key Differences in Data and Rules
The US and Europe both require corporate insiders to disclose their transactions publicly - but the rules, timelines, and data quality differ significantly. Here is what you need to know if you want to track both markets.
At a glance: US vs Europe
| Feature | 🇺🇸 United States | 🇪🇺 Europe (MAR) |
|---|---|---|
| Regulation | Securities Exchange Act / SEC | EU Market Abuse Regulation (MAR 596/2014) |
| Primary filing | Form 4 (corporate), STOCK Act (Congress) | PDMR notification to national regulator |
| Disclosure window | 2 business days (Form 4) | 3 business days |
| Congressional lag | 45 days (STOCK Act) | N/A |
| Central database | SEC EDGAR (centralised) | Each country has own database (fragmented) |
| Languages | English only | National languages (FR, DE, NL, etc.) |
| Price included | Yes (Form 4) | Sometimes (varies by country) |
| Coverage | All US-listed companies | EU/UK-listed companies |
US insider disclosure: SEC Form 4
In the United States, Section 16(a) of the Securities Exchange Act requires that officers, directors, and 10%+ shareholders of public companies report their trades to the SEC. The primary form is Form 4, which must be filed electronically via SEC EDGAR within two business days of the transaction.
Form 4 is highly standardised. It includes the filer's name and title, the security transacted, the number of shares, the price per share, whether the transaction was direct or indirect, and the resulting ownership stake. This makes it straightforward to parse and analyse at scale.
The two-day disclosure window is one of the most aggressive in the world. By comparison, the 45-day window for Congressional trades under the STOCK Act is dramatically looser - long enough for trades to have fully resolved before the public learns about them.
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European insider disclosure: MAR PDMR notifications
The EU Market Abuse Regulation (MAR) requires persons discharging managerial responsibilities (PDMRs) at EU-listed companies to notify their company and the relevant national competent authority (NCA) within three business days of executing a transaction in the company's shares or related financial instruments.
The fundamental difference from the US system is that there is no pan-European equivalent of SEC EDGAR. Each country's national regulator maintains its own database:
- 🇫🇷 France: AMF - Déclarations des opérations sur titres
- 🇩🇪 Germany: BaFin - Directors' Dealings
- 🇳🇱 Netherlands: AFM - Meldingen transacties door leidinggevenden
- 🇧🇪 Belgium: FSMA - Notifications de transactions
- 🇬🇧 United Kingdom: FCA - Directors' Dealings (post-Brexit)
Each of these databases has a different format, different fields, different language, and different update frequency. There is no standard API. Some publish XML feeds; others publish HTML pages; some require scraping. Disclosyr handles all of this normalisation automatically.
Data quality differences
US Form 4 data is generally of higher quality than European MAR data in terms of standardisation. The SEC imposes a strict schema, includes share price in most cases, and EDGAR makes bulk downloads easy.
European data quality varies by country. BaFin Germany is relatively well-structured. AMF France is comprehensive but in French. FSMA Belgium publishes in both French and Dutch. AFM Netherlands has a well-maintained public API. FCA UK is English but in a different format from EU regulators.
One area where European data is often weaker is transaction price. MAR requires disclosure of the price, but some filings include only a value range rather than an exact per-share price. Disclosyr handles this by using the midpoint of ranges where exact prices are unavailable.
Why tracking both markets matters
Most institutional data providers that cover insider trading data focus almost exclusively on the US market. European MAR data is either ignored or available only at significant cost. This creates an information asymmetry: investors who monitor European insider activity systematically have a less crowded, less picked-over dataset to work with.
For companies that are dual-listed or that operate primarily in Europe - ASML, SAP, LVMH, Shell, HSBC, AstraZeneca - the most relevant insider data is European. Following only SEC filings for these companies is incomplete.
Disclosyr is the only tracker that covers both EU and US insider data in a single, normalised, searchable database. Explore both markets in the live feed or compare country-level activity:
Disclaimer: Disclosyr provides public disclosure data and analytics for research purposes only. Nothing on this page constitutes investment advice, a recommendation, or a solicitation to buy or sell any security. Past insider performance does not guarantee future results. Always consult a licensed financial advisor before making investment decisions.