Consob draws the attention of supervised issuers to the impact of the war in Ukraine on insider information and financial reporting (18 March 2022)

Consob draws the attention of supervised issuers to the impact of the war in Ukraine on insider information and financial reporting 

Consob continues to monitor the impact on the financial markets of the war in Ukraine and of the sanctions adopted against Russia and with the other competent national authorities, within ESMA, coordinates the initiatives to be undertaken.

On 14 March 2022, ESMA published a Public Statement[1] on the impacts of the Russian-Ukrainian crisis on the EU financial markets, which illustrates the supervisory and coordination activities undertaken in this context and contains recommendations to issuers.

On the occasion of the approval of the 2021 financial statements and subsequent financial statements, Consob draws the attention of listed companies[2] and other supervised issuers[3] on the following issues coordinated within ESMA:

  • disclose as soon as possible any insider information concerning the impacts of the crisis on fundamentals, prospects and the financial situation, in line with the transparency obligations under the Market Abuse Regulation, unless the conditions for delaying the publication of the insider information are met; and
  • provide information, to the possible extent on both a qualitative and quantitative basis, on the current and foreseeable direct and indirect effects of the crisis on commercial activities, exposures to affected markets, supply chains, financial position and economic results in the 2021 financial reports, if not yet approved, and in the annual shareholders' meeting or otherwise in the interim financial statements.

The auditors and the supervisory bodies are expected to pay particular attention, in the context of the audit of the financial reports, to the issues mentioned above, with particular regard to the effects on the issuer and the subsidiaries of the restrictive measures adopted by the EU[4].

In the light of the recent recommendations issued by the National Cybersecurity Agency[5], the Commission recommends that particular attention should be paid to the assessment of cybersecurity risks.

Therefore, it is appropriate to prepare adequate and effective organizational and technical measures aimed at mitigating this risk, including strengthening the information flows with control bodies.


[2] Reference is made to listed issuers whose home Member State is Italy pursuant to Article 1.w- quater of the Consolidated Law on Finance.

[3] Reference is made to issuers of financial instruments widely distributed among the public pursuant to Article 116 of the Consolidated Law on Finance, to issuers of financial instruments traded on multilateral trading facilities - MTF and on organised trading systems - OTF subject to EU Regulation no. 596/2014 - MAR.