RE: P140 Strengthens Again: More Value, More Leverage1 Apr 2026 08:29
2/2
### Exceptions and Practical Points
- **Clearance outside closed periods**: Directors can usually deal (buy or sell) after obtaining prior written clearance, provided they are not in possession of inside information.
- **Certain transactions** may be exempt (e.g., gifts, inheritance, or automatic exercises under employee share schemes in some cases), but buying on the open market is not.
- **Company-specific policies**: Many companies impose even stricter internal rules than the legal minimum.
- **Consequences of breach**: Regulatory action by the FCA, fines, reputational damage, possible criminal prosecution, and civil claims.
### Summary
- **Allowed?** Only **outside closed periods**, **without inside information**, and usually **after obtaining clearance** under the company's dealing policy.
- **Not allowed at any time**: No — there are explicit prohibitions and procedures that must be followed.
These rules apply to **all UK-listed companies** (Main Market and AIM) and are enforced strictly to maintain market integrity. Unlisted (private) companies have far fewer restrictions, though directors may still owe fiduciary duties and could face issues if they trade on confidential information.
This is a general overview based on UK MAR and AIM Rules as of 2026. Rules can be complex and fact-specific (e.g., depending on the exact timing or type of transaction). Directors should always consult the company's dealing policy, company secretary, or a specialist lawyer/compliance adviser before any share transaction. This is **not legal or financial advice**. For personalised guidance, seek professional advice from a qualified source.