MAR: Written notification (KRT-1801) and explanation of delayed disclosure of inside information
Last published: 31 March 2025
In the case of delayed disclosure of inside information, the issuer shall send a written notification (hereinafter called ‘Notification’) of the delay to Finanstilsynet via Altinn immediately after the information has been disclosed to the public. If requested by Finanstilsynet, the issuer shall also submit a written explanation concerning the delayed disclosure of inside information.
Reporting
Submission of Notification of delayed disclosure to Finanstilsynet (KRT-1801)
A Notification of delayed disclosure of inside information shall be sent to Finanstilsynet upon disclosure of inside information, using Altinn form KRT-1801: Notification to Finanstilsynet by issuers who have delayed the disclosure of inside information (hereinafter referred to as KRT-1801). KRT-1801 shall always be used when submitting a notification of delayed disclosure. Information about how to fill in the Altinn form is provided in help texts included in the form.
By clicking on the link Go to reporting in Altinn (KRT-1801) below, the submitter will gain access to logging in to KRT-1801. The submitter must thereafter log in to their own private user in Altinn and will be asked to choose a login method. The following five login options will appear: MinID, BankID, Buypass, Commfies or Altinn Log in without a national identity number/D-number. Foreigners who do not have a Norwegian national identity number or D-number must choose the last option. (A D-number is a number that can be assigned to foreigners who do not have a Norwegian national identity number but need to verify their identity to Norwegian authorities. D-numbers are assigned by the Norwegian authorities).
When the submitter is logged in to Altinn, it will appear who they can represent in Altinn. In order to represent a Norwegian issuer in Altinn, the submitter must either be registered as having an external role in the Central Coordinating Register for Legal Entities, e.g. the managing director or the board chair, or the submitter must have been delegated a role on behalf of the issuer via its organisation number in Altinn. It is not possible to assign roles to a user who does not have a Norwegian national identity number or D-number. When the submitter opens form KRT-1801 via a Norwegian issuer the submitter represents, the issuer's organisation number will automatically appear in KRT-1801 under section 1.1 Organisation number.
If the submitter is to send a Notification on behalf of a foreign issuer, the submitter must open the form via its own user in Altinn after logging in. For foreign issuers, field 1.1 Organisation number in KRT-1801 shall not be completed. Foreign issuers are identified in KRT-1801 by registering the issuer's LEI code in section 1.2 and the issuer's name in section 1.3.
Please note that for Norwegian issuers, KRT-1801 must always be submitted by a person who has a role within the issuer in Altinn as described above.
Information about logging in to Altinn and Altinn support is available via the links below:
- How can I log in as a business?
- How to give a single service or role to others
- Log in without national identity number / D-number
- User guide for foreigners: How to log in to Altinn.no (pdf)
- Altinn support (in case of technical problems with the form or login)
As mentioned above, KRT-1801 includes help texts for completing the form. The form cannot be submitted until all mandatory fields have been filled in. Once KRT-1801 has been submitted, Altinn will generate a receipt to the submitter for the information reported to Finanstilsynet. If you have any questions about completing the Altinn form, please contact Finanstilsynet at the following e-mail address: mar@finanstilsynet.no.
Explanation to Finanstilsynet of how the conditions for delayed disclosure were met
At Finanstilsynet’s request, the issuer must, in addition to submitting the Altinn form KRT-1801, give a written explanation of the assessments made concerning inside information and the conditions for delayed disclosure (see the section 3-2 of the Securities Trading Regulations amd MAR Article 17 (4) third subparagraph). The explanation shall be sent as soon as possible.
In this context, reference is also made to the Ministry of Finance’s assumption, set out in the preparatory works, saying that the issuer should record and document its assessments of delayed disclosure on an ongoing basis, but that the actual compilation and systematisation of the information for legal justification does not need to be carried out until the supervisory authority requests such justification (see Proposition 96 LS (2018-2019) item 6.8.2.5).
Relevant information
- Public disclosure and delayed disclosure of inside information (continuing information obligations)
- MAR: Delayed disclosure of inside information – issuers
- Insider lists
- Market conduct
- Buy-back programmes
- Stabilisation
- MAR and the emission allowance market
- MAR: Delayed disclosure of inside information – emission allowance market participants
- General information about sanctioning for infringement of the market conduct regulations