29 July 2025 Sarah Debney Capital Markets - Equity

National Storage Mechanism and MAR notification Portal: upcoming changes for issuers

In Primary Market Bulletin 57, the Financial Conduct Authority flags upcoming changes to both the National Storage Mechanism and the delayed disclosure and PDMR notification portal which will impact issuers and their company secretarial teams.

Enhanced metadata requirements in NSM filings

Late last year the FCA published final rules that will, when they come into force on 3 November 2025, introduce more comprehensive metadata requirements for NSM filings. The changes aim to make it easier for NSM users to find regulated information. 

The changes which will affect UK regulated market issuers are as follows:

  • Automated checks of metadata: these checks will include the issuer’s Legal Entity Identifier so issuers must provide their LEI to their Primary Information Provider to avoid the NSM rejecting their disclosures. The same checks will be made to submissions via the Electronic Submission System.
  • LEI ‘issued’ status: issuers will be required to have an LEI with a registration status of ‘issued’. LEIs must be renewed annually to remain compliant. For further information on the LEI renewal process, issuers should refer to guidance provided by their chosen LEI-issuing organisation.
  • Related issuer details: issuers will be required to include in the metadata the name and LEI (if available) of any additional related issuers that are the subject of the disclosure.
  • Corrections: there will be a new facility for issuers to submit corrections to previously filed disclosures via ESS or via a PIP.
  • Headline codes and categories: the list of headline codes and categories used to categorise regulated information will be updated. Issuers must label regulated information accurately when submitting it via a PIP or via ESS.

The FCA expects to publish supporting materials, including updated NSM submitter and user guides, before the changes come into effect.

Note that the facility to upload files to the NSM via ESS will be unavailable during the weekend before the launch of the updated system (1-2 November 2025).

Updating the delayed disclosure and PDMR notification portal

Later this year the FCA will update the delayed disclosure of inside information and persons discharging managerial responsibilities notification portal. The updates will include enhanced validation rules and a change to the order in which information is entered. The changes aim to make the forms easier and quicker for issuers to complete, reduce errors and ensure greater consistency in the information the FCA receives.

The FCA expects to publish further details, including guidance and updated materials, in due course.