On 27 March 2020, the European Securities and Markets Authority (ESMA) issued a Public Statement that addresses the implications of the COVID-19 pandemic on the deadlines for publishing financial reports which apply to listed issuers under the Transparency Directive (TD). You can find ESMA’s Public Statement here: https://www.esma.europa.eu/press-news/esma-news/esma-issues-guidance-financial-reporting-deadlines-in-light-covid-19.
The Danish Government has also addressed the implications of the COVID-19 pandemic by adopting temporary legislation extending the deadlines for registration of financial reports for all companies. The deadlines for disclosure of financial reports for companies admitted to trading at a regulated market as set in the capital markets act are not extended in the amending act[1].
Disclosures under article 17 of the Market Abuse Regulation (MAR)
Issuers shall be aware that they continue to be subject to the disclosure obligations laid down in Article 17 of the Market Abuse Regulation. In particular, issuers must continue to inform the market as soon as possible of any inside information that directly concerns them.
Nasdaq Copenhagen remarks
Nasdaq Copenhagen Surveillance has the following remarks in relation to the deadlines for disclosure of financial reports for issuers of shares and bonds admitted to trading on the Nasdaq Copenhagen main market (regulated market).
Issuers of shares at Nasdaq Copenhagen main market
As of 1 May 2020, issuers of shares at Nasdaq Copenhagen main market has a four (4) month deadline for disclosure of the annual report. At the same time the deadline for interim reports (half-year and quarterly reports) is extended to three (3) months. That is a consequence of the implementation of the Nordic Main Market Rulebook, which was published on 6 March 2020.
Issuers of bonds at Nasdaq Copenhagen main market
To align the requirements for issuers of both shares and bonds the Rulebook for issuers of bonds admitted to trading at Nasdaq Copenhagen main market is adjusted similarly effective 1 May 2020. The deadline for disclosure of the annual report will be changed from three (3) months to four (4) months. The deadline for disclosure of interim reports (half-yearly and quarterly) will be changed from two (2) months to three (3) months.
Issuers of shares at First North Growth Market Copenhagen
For issuers of shares admitted to trading at First North Growth Market Copenhagen, the deadline for disclosure of the annual report is six (6) months. In practice this is restricted by the rules in the companies act requiring companies to approve and register the report within five (5) months. However, with these rules extended by the temporary legislation, the deadline for disclosure of the annual report is the full six (6) month period as stipulated in the rules. Interim reports (half-yearly and quarterly) are subject to a two (2) month deadline. This deadline will temporarily be extended to three (3) months (extension of deadline will cease automatically by 31 December 2020).
The deadlines are summarized in the table:
| Shares, regulated market | Shares, First North GM | Bonds, regulated market | |
| Annual report |
4 months (as of 1 May 2020) |
6 months |
4 months (as of 1 May 2020) |
| Interim reports |
3 months (as of 1 May 2020) |
3 months (temporarily) |
3 months (as of 1 May 2020) |
We encourage all Issuers to contact the Surveillance function should there be any questions regarding the rule books or the information in this letter. You can contact us by telephone + 45 33 93 33 66 or by e-mail.
Kind regards,
Jakob Kaule Marcia Bossen Møller
Head of Surveillance Surveillance
jakob.kaule@nasdaq.com marcia.bossenmoller@nasdaq.com
[1] Amending act: Legislative proposal no. 168A (2019/20) as adopted by the Danish Parliament on 2 April 2020.