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Subject: will trigger the closed period law Из вопросов и ответов (для уяснения требуется широкий контекст):Вопрос: PJSC ХХХ makes the following regular disclosures: a) the Annual Report;
b) Quarterly Reports in accordance with the Federal Law “On the Securities Market”.
c) Annual RAS accounts;
d) Quarterly RAS accounts;
e) IFRS USD-denominated annual and interim consolidated financial statements;
f) RUB-denominated consolidated financial statements in accordance with the provisions of the Federal Law On Consolidated Financial Statements.
g) Beginning from 2017 PJSC ХХХ will be also required to disclose RUB-denominated interim consolidated financial statements in accordance with the provisions of the Federal Law On Consolidated Financial Statements.
h) Moreover, PJSC ХХХ proactively discloses quarterly and annual non-audited financial results based on its management accounts.
Please specify, which of the above-mentioned disclosures should be covered by “closed” periods in accordance with Art. 19(11) of MAR?
Ответ: ESMA interprets the temporal scope of the closed period widely, and its interpretation is that any interim report (e.g., quarterly and half yearly financial report) will trigger the closed period. This interpretation should be taken to encompass all earnings releases, required both in Moscow and in London.
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