No. Nasdaq First North Growth Market is not a regulated market. It is a multilateral trading facility (MTF) registered as an SME growth market. The market is regulated and supervised, but it is not a "regulated market" as EU law uses the term. The difference decides which rules a company must follow.
In short
- "Regulated market" is a legal term in EU law, not the opposite of "unregulated".
- Nasdaq Copenhagen's main market is a regulated market. First North is a multilateral trading facility registered as an SME growth market.
- The Market Abuse Regulation (MAR) applies in full on First North, and Nasdaq's rulebook is binding.
- EU rules that only apply to "regulated markets" do not apply on First North. These include ESEF, mandatory IFRS for consolidated accounts, and the rules on major shareholder notifications and takeover bids.
What does "regulated market" mean?
The EU Markets in Financial Instruments Directive (MiFID II) distinguishes between three kinds of trading venue (Article 4(1), points 21 to 24):
| Trading venue | What it is | Example |
|---|---|---|
| Regulated market | A market authorised and operated under Title III of the directive, with the strictest requirements for issuers | Nasdaq Copenhagen main market |
| Multilateral trading facility (MTF) | A venue operated by an exchange or investment firm under Title II of the directive. Can be registered as an SME growth market | Nasdaq First North Growth Market |
| Organised trading facility (OTF) | A venue for bonds, structured products, emission allowances and derivatives, not shares | Not relevant for shares |
All three are trading venues and all three are regulated. But many EU rules only apply to "issuers whose securities are admitted to trading on a regulated market". Those rules do not reach companies on First North.
Why is First North not a regulated market?
Because it is designed for smaller growth companies. Nasdaq operates First North as an SME growth market under MiFID II, so smaller companies can list without the costs and requirements that come with the main market. Nasdaq says so in the introduction to its rulebook: First North is "not a 'regulated market', as defined in EU legislation".
The same difference appears in the disclaimer every Company Description for a First North listing must include. It states that issuers on First North are not subject to all the same rules as issuers on the main market, but to a less extensive set of rules, and that the risk of investing may therefore be higher (Rulebook, Appendix D).
So is First North unregulated?
No. First North is regulated, just differently from the main market:
- MAR applies in full. Companies on First North must publish inside information and keep insider lists, and management is subject to the rules on closed periods and reporting their own trades.
- Nasdaq's rulebook is binding. It sets deadlines for the annual and half-year reports, website requirements and the duty to have a Certified Adviser, among other things. Breaches can lead to a reprimand, fines of up to DKK 1 million or, in serious cases, removal from trading (Rulebook, 8.2 and Supplement D, 8.3.3).
- The Danish FSA supervises. Supervision covers both Nasdaq as the market operator and compliance with MAR.
What the difference means in practice
| Area | Main market (regulated market) | First North Denmark (MTF) |
|---|---|---|
| Market Abuse Regulation (MAR) | Applies | Applies |
| Annual and half-year reports | Required by the Capital Markets Act and filed in the FSA's OAM system | Required by Nasdaq's rulebook. Not filed in OAM |
| ESEF (iXBRL format) | Required | Not required |
| IFRS in consolidated accounts | Required by the IAS Regulation | Not required, except in the Premier segment |
| Danish reporting class D | Yes | No, not by virtue of the listing |
| Major shareholder notifications under the Capital Markets Act | Required | Not required |
| Danish takeover bid rules | Apply | Do not apply |
| Certified Adviser | No | Required |
The table covers capital markets rules. The Danish Companies Act and Financial Statements Act apply to all Danish companies regardless of trading venue, so, for example, the rules on general meetings and filing the annual report with the Danish Business Authority also apply on First North.
"Listed" means two things
In everyday language, a company on First North is listed. Its shares trade on Nasdaq, and it has shareholders, a share price and investor relations. That is also how we use the word on this site.
In legislation, however, "listed" usually means admitted to trading on a regulated market. When the Danish Financial Statements Act refers to listed companies in reporting class D, First North companies are not included. The Danish Business Authority states directly that First North is not defined as a regulated market, so companies listed on First North are not in reporting class D.
What about First North Premier?
First North Premier Growth Market is a segment within First North for companies that choose stricter requirements. Companies in the Premier segment must use IFRS and follow the main market's disclosure rules instead of Chapter 4 of the First North rulebook (Rulebook, 7.2.1 and 7.3.1). Legally, though, they are still on a multilateral trading facility, so EU rules tied to a regulated market still do not apply automatically.
What it means for your reporting
For a First North company, Nasdaq's rulebook sets the deadlines and requirements for the annual report, half-year report and financial calendar, while MAR governs how you handle inside information. Read our guides to the annual report and the financial calendar, or see how we help First North companies.
Sources
- MiFID II, Directive 2014/65/EU (opens in a new tab), Article 4(1), points 21 to 24 (definitions of trading venues) and Article 33 (SME growth markets)
- Nasdaq: First North MTF Rules (opens in a new tab) (always lists the rulebook currently in force)
- Nasdaq First North Growth Market Rulebook for Issuers of Shares, 1 October 2026 (opens in a new tab), the version this article is based on (Introduction, Chapters 7 and 8, Supplement D and Appendix D)
- Danish FSA: Issuers' disclosure and reporting obligations (opens in a new tab) (in Danish; main market compared with First North Denmark)
- Danish Tax Agency: Regulated market and multilateral trading facility explained (opens in a new tab) (in Danish)
- Danish Business Authority: Guidance on annual reports (opens in a new tab) (in Danish; First North and reporting class D)
- ESMA: Electronic Reporting (ESEF) (opens in a new tab) and the scope of the Transparency Directive (opens in a new tab)
- IAS Regulation (EC) No 1606/2002 (opens in a new tab), Article 4
- Market Abuse Regulation (EU) No 596/2014 (opens in a new tab)
About this article: The content is general information, not legal, accounting or other professional advice. It reflects the rules as they stood when it was published on 22 October 2026, and rules and practice may have changed since. Venari Digital cannot be held liable for decisions made on the basis of this content. Always consult your Certified Adviser, auditor or legal adviser before acting.