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Price-sensitive information meaning

What does Price-sensitive information mean?
Information about an issuer or its securities that, if made public, would be likely to move the market price materially. In practice, lawyers use the term to flag information that must be kept confidential, restrict dealing, or be announced without delay. In UK financial regulation the operative concept is “inside information”, defined in the UK Market Abuse Regulation (UK MAR, Article 7) and applied through the FCA Disclosure Guidance and Transparency Rules (DTR). In Ireland, the equivalent definition in the EU Market Abuse Regulation (EU MAR) applies. Although “price-sensitive information” is not a statutory term, it remains used in the City Code on Takeovers and Mergers (see Rule 2.1(a) and Notes to Rules 4.1 and 4.2) and in Irish takeover practice to govern conduct and announcements during an offer period. Key features mirror the inside information test: the information is non-public, precise, relates directly or indirectly to the issuer or its financial instruments, and would be likely to have a significant effect on price (often expressed as the reasonable investor test). Usage and practical significance are broadly consistent across England & Wales, Scotland, Northern Ireland and Ireland: it underpins disclosure obligations, insider lists, wall‑crossing, dealing restrictions and market abuse/insider dealing risk management.
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View the related Checklists about Price-sensitive information

CHECKLISTS
UK print marketing campaigns: practitioner checklist on targeting, placement, agency contracts, data protection, DMCCA 2024/CAP Code compliance, comparative claims, IP, prize/price promotions and clearance

This Checklist supports planning for a print marketing campaign. It concentrates on marketing-specific needs, excluding wider transactional matters (eg contract formation, distance selling). Scope includes targeting and placement, agency agreements, data protection, advertising compliance, and prize or price promotions. It also addresses conformity with the UK’s legislative and self-regulatory framework, notably the unfair commercial practices rules in the Digital Markets, Competition and Consumers Act 2024 (DMCCA 2024) and the UK Code of Non-broadcast Advertising and Direct & Promotional Marketing (CAP Code). Print ads remain pivotal to big-brand activity, across billboards, posters, brochures, leaflets, newspapers and magazines. In the UK, print advertising is overseen through a blend of industry self-regulation and statute. For a wider briefing on the UK advertising environment, see Practice Note: Advertising law and regulation. See also: Advertising copy approval—checklist; Planning a digital marketing campaign—checklist. A third column is available to capture observations or remarks while working through the Checklist... Checklist Further information Notes (if any) Targeting and placement ...

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CHECKLISTS
FCA Consumer Duty Fair Value: Checklist for PRIN 2A.4 Assessments Covering Manufacturers, Distributors, Target Markets, Pricing, Vulnerable Customers, Closed Products and Governance

This checklist helps practitioners grasp and consistently apply the FCA’s Consumer Duty requirements for evidencing fair value effectively. It should be considered alongside other relevant practical Consumer Duty materials and references: for information on the main elements of the Consumer Duty with general application, see Practice Note: The FCA Consumer Duty—essentials; also for a suite of sectoral guidance and checklists see: Consumer protection and FCA Consumer Duty—overview for key developments relating to the FCA’s Consumer Duty, see: The FCA Consumer Duty—timeline Background Under the Consumer Duty, four outcomes cover the central and key aspects of the firm–customer relationship. The second outcome is the Price and Value Outcome, which is concerned with an overarching obligation that products must deliver ‘fair value’ to customers. Under PRIN 2A.4: value is the relationship between the amount paid by a retail customer for the product and the benefits they can reasonably expect to receive from the product; and a product provides fair value...

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CHECKLISTS
Price Promotions, Sales and Comparative Claims: UK Compliance Checklist (CMA/ASA; DMCCA 2024)

Checklist This Checklist covers key points practitioners should weigh up when reviewing price promotions. Such activity could include free extra volume or money-off offers, among other common mechanics. It reflects requirements set out in the Competition and Market’s Authority guidance, Price transparency: CMA209 (Price Transparency Guidance). For more detail, see Practice Note: Promotional marketing and price claims. As you progress through the Checklist, the third column can be used to note observations or comments. Basic issues to consider for price and value promotions Is the promotion a bona fide price reduction or an increase in volume running for a specified period? Marketers and traders should retain relevant evidence to show the claim is authentic. Is the promotion presented clearly and not misleading? Include all qualifications, restrictions or other limitations that affect availability. Link to relevant terms and conditions for further detail, but do not rely on them for any material pricing information or restrictions; these must be stated clearly within the promotion...

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FLOWCHARTS
Final Payment Process under JCT Design and Build Contract 2011 — Archived Flowchart

Clause 20.2 claims flowchart summary (FIDIC 2017) This flowchart describes the process for claims by the Contractor or Employer under clause 20.2 of the FIDIC Red and Yellow Books 2017, and applies to the following: Employer claims for the following: additional payment or a decrease in the Contract Price; and/or an extension of the Defects Notification Period Contractor claims for the following: additional payment; and/or an extension to the Time for Completion The party making a claim must also meet any specific requirements found in the clause setting out the relevant entitlement. For more information, see Practice Note: FIDIC contracts 2017—Contractor and Employer claims...

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NEWS
CMA draft pricing guidance: delivery charges and the DMCC total price requirement across product listings, baskets and checkouts (UK)

Overriding principles The DMCC’s core requirement is that a product’s “total price” must be shown prominently in every invitation to purchase (ITP). (For what constitutes an ITP, see here.) The total price covers all amounts the consumer will inevitably pay, which therefore includes any compulsory delivery charges. There is a limited DMCC exception. Where, owing to the nature of the product, a compulsory delivery charge cannot reasonably be worked out in advance, every ITP must explain how that charge will be calculated. This explanation must appear with the same prominence as the total price and must enable the consumer to determine the overall cost. Typically, equal prominence means placing this information beside or immediately below the total price. Before relying on this carve‑out, traders should be satisfied that the compulsory delivery charge genuinely cannot be calculated beforehand. The CMA has indicated that the exception will be applied narrowly...

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NEWS
UK Data (Use and Access) Act 2025: Implications for Pension Schemes—DSARs, Complaints, ICO Powers, ADM, Recognised Legitimate Interests, Marketing, Special Category Data, Purpose Limitation and Practical Steps

What are the most significant changes introduced by the Act that pension scheme trustees need to prepare for? The most notable reforms in the Act that trustees should be ready for are: Data subject complaints: complaints about the handling of personal data must be acknowledged within 30 days and answered without undue delay. ICO enforcement powers: the Information Commissioner’s Office (ICO) now has authority to compel interviews and require the production of documents to assess compliance. Data subject access requests (DSARs): the Act codifies the ICO’s existing guidance, meaning (i) trustees must apply a ‘reasonable and proportionate’ search standard when responding; and (ii) the ‘stop the clock’ rule pauses the one-month deadline for a response. Automated decision making (ADM): the Act allows reliance on the full set of lawful bases — including ‘legitimate interests’ — when non-special category personal data is used for significant automated decisions about an individual, provided suitable safeguards are in place. ...

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NEWS
UK corporate crime weekly: LIBOR convictions quashed, OFSI enforcement reforms, crypto action, Criminal Procedure Rules 2025, ransomware proposals, water sector overhaul, NCA priorities, Companies House removals, 24 July 2025

In this issue: Investigating criminal conduct Criminal procedure and evidence Proceeds of crime Sentencing Bribery, corruption, sanctions and export controls Consumer protection and cartels Cybercrime and data protection offences Environmental offences Financial services and pensions offences Health and safety and corporate manslaughter offences Insolvency offences and Companies Act offences Money laundering International Other corporate crime news Daily and weekly news alerts New and updated content Dates for your diary Trackers Useful information Investigating criminal conduct Standards of candour in closed hearings, and corporate witness statements (Attorney General v BBC; R (‘Beth’) v IPT) When scrutinising MI5’s actions across two High Court cases, the court addressed the grave consequences of presenting inaccurate material within closed hearings. It outlined the tightly confined situations that can justify a departure from open justice under section 6 of the Justice and Security Act 2013 (JSA 2013). The court further...

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View the related Practice Notes about Price-sensitive information

PRACTICE NOTES
UK DTR 2: issuer obligations on disclosure, delay, control and selective disclosure of inside information—FCA/ESMA guidance, case law, COVID‑19 context and enforcement (post‑Brexit UK MAR)

Resource Note This Resource Note signposts key commentary, analysis and materials to aid interpretation and offer practical direction on using Chapter 2 of the Disclosure Guidance and Transparency Rules (DTR 2). Where relevant, it draws on: the Financial Conduct Authority (FCA) Handbook FCA Knowledge Base—Procedural and Technical notes (formal guidance binding on the FCA) FCA consultation and discussion papers, policy and feedback statements, and warnings Primary Market Bulletins and other FCA publications legacy UKLA technical and procedural notes and the UKLA’s newsletter List!, where still pertinent assimilated EU legislation EU Directives and EU Regulations, where helpful to construing a provision Lexis+® UK analysis and resources Setting the scene What it covers: DTR 2 prescribes the framework for issuers to disclose and manage inside information, supporting timely and even-handed release of market-sensitive information. It also identifies specific situations permitting a delay to public disclosure of inside information, together with the safeguards required to keep such information...

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PRACTICE NOTES
The criminal cartel offence in the UK: pre-2014 dishonesty test, ERRA 2013 reforms, statutory exclusions and defences, CMA/SFO MoU, prosecution guidance and immunity

The creation of the Competition and Market Authority (CMA) in 2013 The establishment of the Competition and Market Authority (CMA) in 2013 coincided with an overhaul of a component of the criminal cartel offence that prosecutors had to prove to convict directors and officers. When the Enterprise and Regulatory Reform Act 2013 (ERRA 2013) commenced on 1 April 2014, the dishonesty element of the cartel offence was scrapped, marking a radical change to what prosecutors had previously been required to establish. Under the revised regime, an individual commits the offence by agreeing, with one or more persons, that two or more undertakings will take part in specified prohibited cartel arrangements (price-fixing, market-sharing, bid-rigging, or limiting output), regardless of dishonesty. Any such arrangements must have occurred in the UK to be caught. As explained further below, this shift is partly offset by new exceptions, covering notification of customers, publication of arrangements, and compliance with a legal requirement, as well as defences, including that the accused did not intend to conceal...

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PRACTICE NOTES
SRA Publicity and Marketing Requirements for Solicitors’ Firms: accuracy, pricing transparency, regulatory status, no win, no fee, public approaches, complaints, third‑party marketing (England and Wales)

This Practice Note is aimed at law firms. It encapsulates the publicity obligations in the SRA Standards and Regulations, together with associated SRA guidance and warning notices. In essence, you must ensure that any publicity about your practice accords with the SRA Principles, particularly by acting in a manner that sustains public trust and confidence in the solicitors’ profession and with honesty and integrity. When delivering services to the public, or a section of it, you must also ensure that publicity about your practice is accurate and not misleading, including any statements about your charges and the situations in which interest is payable by or to clients. There are additional requirements concerning letterheads, how staff are described, your regulatory status, and price and service information, etc, which apply more broadly. See also Precedent: Publicity policy—law firms. What is publicity? Publicity includes: all promotional material and activity, including the name or description of your firm stationery advertisements brochures websites directory entries...

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View the related Precedents about Price-sensitive information

PRECEDENTS
SRA-compliant Fixed-Fee Price and Service Information Notice Template for Law Firms (England and Wales)

1 Legal costs 1.1 The legal costs of [ insert brief description of services, eg obtaining a grant of probate and distributing an estate ] consist of [ two OR three ] principal elements: our fees; outlays we pay on your behalf (often referred to as disbursements) [ ; OR . ] [ costs you may need to pay to another party. ] 1.2 Our charges We apply a fixed-fee structure [ of £[ insert price excluding VAT ] OR ranging between £[ insert price excluding VAT ] and £[ insert price excluding VAT ] depending on [ insert description of the factors that will dictate where in the fixed price range your fees will fall, eg the value and complexity of your matter ] ] . [ If a matter or transaction does not reach completion, we reserve the right to charge for the work undertaken, using our standard charging rate of £[ insert rate...

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PRECEDENTS
Pro-supplier framework services agreement with call-off orders (single-contract), including data protection and economic crime compliance schedules — England and Wales

Dated [ date ], this Agreement is entered into between the parties identified below. Parties [ insert name of Customer ] [ of OR a company incorporated in [ England and Wales ] with registered number [ insert registered number ] and whose registered office is at [ insert address ] ] (the Customer) [ insert name of Supplier ] [ of OR a company incorporated in [ England and Wales ] with registered number [ insert registered number ] and whose registered office is at [ insert address ] ] (the Supplier) Each of the Supplier and the Customer is a party; together, they are the parties. Background The Customer carries on the business of [ insert description ]. The Supplier conducts the business of providing [ insert description of services ] to other businesses. The parties have agreed that the Supplier will provide services to the Customer on the terms contained in this Agreement....

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PRECEDENTS
Schedule of Employer‑Favouring Amendments to JCT SBC/AQ 2016 (England): Building Safety Act/HRB, Dutyholder and CDM compliance; design liability; collateral warranties; insurance; payment; insolvency; adjudication (arbitration removed)

The Contract comprises the completed Standard Building Contract With Approximate Quantities 2016 published by the JCT subject to the following amendments: This Contract adopts JCT SBC/AQ 2016 with extensive modifications to reflect design responsibility, building safety and commercial controls. Recitals: Contractor to provide a master programme and Schedule of Information Requirements; confirms site due diligence and accepts full CDP design liability. Articles: Dutyholder Regulations added; Tender Price covers Principal Contractor duties; arbitration removed; Schedule of Amendments prevails; strict protection of Third Party Agreements. Definitions/governance: new and revised terms (Building Safety Regulator, HRB, Practical Completion, Copyright Material, Design Sub‑contractors, Dutyholder Regulations); several deletions; English court jurisdiction. Design/materials/information: skill‑and‑care design and coordination; only new, compliant, non‑deleterious materials; golden thread storage; monthly programme reporting; site risks at Contractor’s risk. Procedures/controls: tighter instruction, testing, defects and as‑built duties; enhanced confidentiality and IP licences; HRB assistance; CDM/Dutyholder competency confirmations. Sub‑contracting/rights: prescribed sub‑contracts, insurances and delivery of collateral warranties/third‑party rights; limits on assignment. Payment/commercial: 28‑day final...

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Q&As
SDLT: Mixed‑use freehold (leased shop + flat) — 3% surcharge avoided?

Mary Ashley of 15 Old Square Higher SDLT rates apply where an individual buys a major interest in a single dwelling if conditions A–D are met at day‑end: A — consideration of £40,000 or more B — not subject to a lease with over 21 years unexpired C — purchaser owns another £40,000+ dwelling not so leased D — does not replace the only or main residence Dwelling includes a building or part used, suitable or being built/adapted as one dwelling, its gardens, grounds and benefiting land, and off‑plan contracts. Mixed‑use is excluded; no apportionment. As this freehold includes residential and non‑residential parts, it is mixed‑use, so the 3% surcharge should not arise. Sean Randall of Blick Rothenberg Limited The 3% applies to “higher rates transactions” in FA 2003, Sch 4ZA, paras 3–7, each requiring the main subject‑matter to consist of a major interest in at least one dwelling. The chargeable interest includes the first‑floor flat but does...

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