Regulating issuers’ disclosure of inside information: the diverging approaches in the European Union and the United States

Capital markets regulation in the European Union and in the United States has progressively converged in a variety of areas. Lawmakers in the two legal systems recognize the vital importance of investor protection and transparency for the correct functioning of the financial markets and have adopted legal instruments to increase market efficiency that are often based on common grounds. Nevertheless, disclosure obligations on material corporate information continue to show differences on either side of the Atlantic, and corporate compliance in that respect is based on different rules for US and for EU companies.