Kinds of dates
Event date versus disclosure date
Short answer
- Event date
- The day the reportable event occurs, such as the Form 8-K Date of Report 1
- Disclosure date
- The day the public is informed, as required by rules such as MAR Article 17 2
- US gap
- Up to four business days for Form 8-K 1
- Canada gap
- News release immediately, report within 10 days 3
- Australia
- Tell ASX immediately, read as promptly and without delay 5
- Hong Kong
- As soon as reasonably practicable 6
Two dates, two questions
Many official records answer two questions. When did it happen, and when did people learn about it. The first is the event date. The second is the disclosure date. In securities filings the two are kept apart on purpose.
The US Form 8-K shows this on its cover page. The form asks for the Date of Report, which it defines as the date of earliest event reported 1. The filing itself can come up to four business days later 1. A reader who copies only one date into a timeline loses part of the record.
How rules set the gap
Each market sets its own gap between event and disclosure. Some use a fixed count of days. Others use a standard such as as soon as possible.
| Jurisdiction | Rule | Timing wording |
|---|---|---|
| United States | Form 8-K General Instruction B.1 1 | Within four business days after the event 1 |
| European Union | MAR Article 17(1) 2 | As soon as possible 2 |
| Canada | NI 51-102 section 7.1 3 | News release immediately, report within 10 days of the change 3 |
| Australia | ASX Listing Rule 3.1 5 | Immediately, meaning promptly and without delay 5 |
| Hong Kong | SFO section 307B 6 | As soon as reasonably practicable 6 |
When the trigger is a decision, not an event
Some rules start the clock at a decision date. Under Item 1.05 of Form 8-K, a cybersecurity incident is reported within four business days after the company determines it is material, not after the incident itself 1. The determination must be made without unreasonable delay after discovery 1. So one incident can carry three dates. The incident date, the discovery date and the determination date.
Canada counts from the change itself. NI 51-102 asks for a material change report as soon as practicable, and in any event within 10 days of the date on which the change occurs 3. Its definition of material change includes a decision to make a change by the board, or by senior management who believe board confirmation is probable 3.
Delayed disclosure creates a third date
Where rules allow delay, there can be a gap of weeks between the event and the announcement. Under MAR, an issuer may delay on its own responsibility if disclosure would prejudice its legitimate interests, delay would not mislead the public and it can keep the information confidential 2.
Canada allows a confidential material change report where disclosure would be unduly detrimental to the issuer, filed with written reasons for non-disclosure 3. ASX lists exceptions for confidential information such as an incomplete proposal or negotiation 5. In each case the record of the delay has its own date, separate from both the event and the eventual announcement.
Filing date is a system date
The date a regulator stamps on a filing follows the rules of its filing system. On the US EDGAR system, direct transmissions that start after 5:30 p.m. Eastern time are deemed filed as of the next business day 4. A filing sent at 6 p.m. on a Tuesday carries the next business day's filing date under that rule 4.
When you cite a filing, give the event date from the document and the filing date from the system, and say which is which.
Common questions
What is an event date?
The date something reportable happened. On Form 8-K it is the Date of Report, the date of earliest event reported 1.
What is a disclosure date?
The date the information was made public, for example under MAR Article 17, which requires disclosure as soon as possible 2.
Can the disclosure come weeks after the event?
Yes, where delay is lawful. MAR allows delay if three conditions are met 2. Canada allows a confidential report with written reasons 3.
Why does an EDGAR filing show the next day's date?
Direct transmissions starting after 5:30 p.m. Eastern are deemed filed the next business day 4.
Rules and charges change. Check the official source linked on this page before you pay or travel. Spotted an error? Email hello@datedrecord.com.
Sources
- US SEC: Form 8-K Current Report Pursuant to Section 13 or 15(d) of the Securities Exchange Act of 1934, General Instructions
- EUR-Lex: Regulation (EU) No 596/2014 on market abuse, consolidated text (4 December 2024)
- Manitoba Securities Commission: National Instrument 51-102 Continuous Disclosure Obligations, unofficial consolidation (18 November 2020)
- eCFR: 17 CFR Part 232, Regulation S-T
- ASX: Listing Rules Guidance Note 8, Continuous Disclosure: Listing Rules 3.1 - 3.1B (amended 5 June 2021)
- Securities and Futures Commission: Guidelines on Disclosure of Inside Information (June 2012)
Related
- Effective date versus commencement date
How laws carry several dates, from assent to commencement, entry into force, application and compliance, with UK, Canada, Germany, EU and US examples.
- Form 8-K timing explained
How the US Form 8-K four business day clock works, when it starts, what the cover page date means and how EDGAR decides the filing date.
- Disclosure deadlines compared
Side by side: how the US, EU, UK, Canada, Australia, Hong Kong and Singapore time the disclosure of material events by listed companies.
- How to build a sourced timeline
A method for building a timeline from filings, laws and statistics: which date to record, how to write it, and how to cite the version you read.