Overview
Primary Market Bulletin 59 led with two headline numbers: delayed disclosure notifications fell 39%, and the average delay stretched to 35.2 days. Neither figure tells you much on its own. The real story is in the category breakdown beneath them, and that's where you can actually see how issuers are behaving.. You can read the full bulletin here.
Nine Categories of Delayed Disclosure
Bulletin 59 sorts Delayed Disclosure of Inside Information (DDII) notifications submitted over a two-year review period, from 1 April 2022 to 31 March 2024, into nine categories based on the type of information involved.
Three categories carried the highest volumes, the FCA reports: Mergers and Acquisitions, Business Updates, and Placings and other Corporate Finance. At the other end, PDMR Shareholdings, a category introduced for this review to capture delayed disclosure within persons discharging managerial responsibilities (PDMR) notifications, attracted just two.
The Categories Where Delay Does Its Job
That top three is not a surprise once you sit with what these categories actually involve. A merger negotiation, a placing, or a material business update are precisely the situations where immediate disclosure would prejudice an issuer's legitimate interests, the first of the three conditions Article 17.4 of UK MAR sets for delay. Deal processes need confidentiality to function, so it tracks that they generate the bulk of legitimate DDII use, and the FCA's data confirms issuers are reaching for delay in the cases the regulation was built to accommodate.
PDMR Shareholdings sits at the other extreme, and the gap deserves a second look. Article 19.1 of UK MAR requires PDMR notifications to be made promptly and no later than three working days after the transaction. A near-total absence of delayed disclosure notifications in this category over a two-year period, across every issuer on the London Stock Exchange Main Market, AIM, the Aquis markets and the Non-AIM MTF, is a striking floor for a nine-strong list. It could mean PDMR-related inside information is genuinely rare, or that issuers are disclosing it promptly rather than delaying it, both of which are consistent with good practice. The FCA does not read it as a red flag in the bulletin, and instead uses the low count as a prompt to restate the three-day rule. Given how few notifications exist to demonstrate that the delay route is even being considered, that restatement is worth an issuer's attention on its own terms.
Delay Periods by Category
Volume tells you where issuers use delay. Length tells you how long confidentiality has to hold, and the two do not move together in the same way across every category.
Unscheduled Financial Information saw its average delay fall by around 6 days to roughly 15, and Periodic Financial Information fell by around 3 days to a similar figure, both moving against the overall trend of a 7 day increase to 35.2 days. Financial information categories are getting faster while the average across all nine categories gets slower, which points to the deal-related categories, where volumes are highest, doing most of the work in stretching the overall figure. Confidentiality on a live transaction can reasonably run longer than confidentiality on a set of results, and the category data, set out in full in the bulletin, appears to reflect that distinction.
Why This Sits Close to Insider Dealing, Not Just Disclosure Timing
DDII notifications are not just a disclosure timing exercise for the FCA. The regulator states plainly that it uses them to monitor compliance with Article 8 (insider dealing) and Article 10 (unlawful disclosure of inside information) as well as Article 17.4 itself, which puts the category data squarely inside the FCA's insider dealing surveillance rather than alongside it. Every day a piece of inside information sits in delay is a day it needs an insider list under Article 18 to control who holds it, and the bulletin repeats that reminder directly: issuers must maintain insider lists during the delay period to reduce the risk of unlawful disclosure and insider dealing while confidentiality still needs to hold. The heaviest categories by volume, Mergers and Acquisitions and Placings, are also the categories where the widest circle of advisers, financiers and internal staff typically has access to the information, which makes the insider list the practical control doing the work behind the disclosure timeline.
A second, quieter point runs the same direction in the bulletin's outliers section. The FCA followed up with issuers showing unusual patterns in delay length, notification timing or notification volume, and found that the main driver was not misconduct but a lack of confidence in classifying and processing inside information, leading to unnecessary notifications. That is a systems and training gap as much as a judgement call, and it sits upstream of the insider list itself: an issuer that cannot classify inside information confidently is also the issuer most likely to be slow, or wrong, about who goes on the list and when they come off it.
What This Means for Your Own DDII Record
For a compliance team, the practical value of this breakdown is a benchmark. If your own DDII notifications cluster where the FCA's do, in deal and corporate finance categories, that is consistent with the market-wide pattern the regulator has just published. If they do not, or if a category with a low FCA-wide count is a recurring feature of your own disclosure log, it is worth being able to show the reasoning behind each delay decision on request, since Article 17.4 requires exactly that written explanation if the FCA asks for one. Keeping that reasoning attached to the record from the moment the decision is made, rather than reconstructing it later, is the difference between a five-minute response to a regulator's query and a scramble through old emails. The same applies to the insider list behind each delay: if the list and the delay decision live in different places, closing one out cleanly when the other changes gets harder every time.
If your insider list and disclosure records live across several systems, that reconstruction is usually where the time goes. InsiderList keeps the delay decision, the rationale, and the insider list for that piece of information on the same record, so the explanation the FCA might ask for is already there when you need it.