First North Denmark: Information regarding deadlines for financial reporting from Nasdaq Copenhagen Surveillance

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-r
eporting-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       Shares, First       Bonds, regulated   
                      market               North GM               market        
--------------------------------------------------------------------------------
Annual report  4 months (as of 1 May       6 months        4 months (as of 1 May
                       2020)                                       2020)        
--------------------------------------------------------------------------------
   Interim     3 months (as of 1 May       3 months        3 months (as of 1 May
   reports             2020)             (temporarily)             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

[e-mail]                                       
[e-mail] 





[1]Amending act: Legislative proposal no. 168A (2019/20) as adopted by the
Danish Parliament on 2 April 2020.

Attachment:
https://cns.omxgroup.com/cds/DisclosureAttachmentServlet?messageAttachmentId=767844