Reading a PDMR notification against the dealing register

When a notification reaches the market, the company secretary’s file should already hold a matching register line. In practice the two drift: trade dates slip by a day, volumes are rounded, or a related person is named in one place and not the other.

Start with the register line

Open the dealing register for the PDMR. Confirm the trade date, instrument, volume, price, and nature of the transaction. Note whether the entry cites a clearance reference. If the register is silent on clearance, record that silence — do not invent a clearance from memory.

Open the lodged notification

Compare each field in the public notification with the register. Pay particular attention to the date of the transaction versus the date of notification, and to any place where “closely associated person” wording appears only on one side.

Check the insider list timing

Ask whether the person was on the insider list on the trade date for any matter that could constitute inside information. A clean PDMR notification does not, by itself, answer that question — but a review that ignores the list is incomplete.

Record exceptions for counsel

Where fields disagree, write the discrepancy with both source references. That schedule is what an insider dealing and filings review later expands into a full chronology.