Firm Trade Surveillance Under MAR: Expectations Are Rising 

Since its introduction in 2016, the EU Market Abuse Regulation (MAR) has set the standard for protecting market integrity, transparency, and investor confidence. While recent reforms under the EU Listing Act aim to reduce unnecessary administrative burden, expectations around firm trade surveillance, evidence, and timely supervisory action remain firmly in place. 

For firms, trade surveillance is no longer a periodic control. It is a continuous obligation that must scale across products, venues, and jurisdictions. 

MAR applies across regulated markets, multilateral trading facilities, organized trading facilities, and relevant over the counter trading activity warning. 

• Ongoing monitoring of trades and orders and submission of Suspicious Transaction and Order Reports where concerns arise 

• Maintenance of real time insider lists and controls over access to inside information 

• Oversight of market soundings and pre transaction communications 

• Supervision of transactions by Persons Discharging Managerial Responsibilities, including enforcement of closed periods 

These requirements mean firm trade surveillance must operate in close coordination with governance, accountability, and information control frameworks. 

What Has Changed and What Has Not 

The EU Listing Act introduces targeted updates intended to simplify compliance, particularly for smaller issuers and small to medium enterprise growth markets. Changes include clearer guidance on delayed disclosure of inside information, adjusted notification thresholds for Person Discharging Managerial Responsibilities (PDMR) transactions, and reduced insider list requirements in certain cases. 

What has not changed is regulatory scrutiny. Firms are still expected to identify suspicious behavior, investigate promptly, and clearly evidence decision making. Simplification of the process does not reduce supervisory expectations. 

Where Regulators Are Focusing Now 

Regulators continue to sharpen their focus on the quality and effectiveness of firm trade surveillance, including: 

• Monitoring activity across regulated markets, Multilateral Trading Facilities (MTFs), and Organized Trading Facilities (OTFs) 

• Detecting misleading trading behavior such as spoofing, layering, and pump and dump schemes 

• Identifying cross market manipulation involving derivatives and related instruments 

• Leveraging advanced analytics and RegTech to detect patterns of concern 

As supervisory authorities increasingly rely on data driven monitoring, firms are expected to demonstrate surveillance programs that are timely, risk-based, and defensible. 

How StarCompliance Can Help 

StarCompliance (Star) modernizes firm trade surveillance by automating detection, reducing false positives, and centralizing oversight within a single workflow. 

With Star, firms can: 

• Apply configurable rules and thresholds to focus on meaningful risk 

• Leverage enriched and aggregated trade data to identify patterns beyond individual transactions 

• Integrate watch lists, restricted lists, and firm trade alerts for consistent oversight 

• Manage investigations and evidence decisions through built in case management 

Firm Trade Surveillance is fully integrated within StarCompliance Enterprise, unifying firm and employee monitoring to support stronger governance and clearer proof under MAR. 

To learn more about Star’s Firm Trade Surveillance and how it can support your firm needs, click HERE for a demo.