Practical Guide
National rules on notifications of major holdings under the Transparency
Directive
ESMA31-67-535 | 15 December 2022
2
Table of Contents
Introduction .............................................................................................................................. 6
PART I: ...................................................................................................................................... 7
COUNTRY-BY-COUNTRY SUMMARY OF NATIONAL REQUIREMENTS REGARDING
NOTIFICATIONS OF MAJOR HOLDINGS UNDER NATIONAL LAW IN
ACCORDANCE WITH THE TRANSPARENCY DIRECTIVE ............................................ 7
Austria .................................................................................................................................... 8
Belgium................................................................................................................................. 10
Bulgaria ................................................................................................................................ 12
Croatia .................................................................................................................................. 14
Cyprus .................................................................................................................................. 16
Czech Republic .................................................................................................................... 18
Denmark ............................................................................................................................... 20
Estonia.................................................................................................................................. 23
Finland .................................................................................................................................. 25
France .................................................................................................................................. 27
Germany ............................................................................................................................... 30
Greece .................................................................................................................................. 32
Hungary ................................................................................................................................ 34
Iceland .................................................................................................................................. 36
Ireland................................................................................................................................... 38
Italy ....................................................................................................................................... 41
Latvia .................................................................................................................................... 44
Lithuania ............................................................................................................................... 46
Luxembourg ......................................................................................................................... 49
Malta ..................................................................................................................................... 51
Netherlands .......................................................................................................................... 54
Norway ................................................................................................................................. 56
Poland .................................................................................................................................. 59
Date: 15 December 2022
ESMA31-67-535
3
Portugal ................................................................................................................................ 61
Romania ............................................................................................................................... 63
Slovakia ................................................................................................................................ 66
Slovenia ................................................................................................................................ 69
Spain .................................................................................................................................... 71
Sweden................................................................................................................................. 74
PART II: ................................................................................................................................... 77
TRANSVERSAL TABLES ...................................................................................................... 77
Table 1: Applicable notification thresholds under TD Article 9............................................ 78
Table 2: Triggering event under TD Art. 9(1) ...................................................................... 80
Table 3: Triggering event in cases where the exercise of a physically settled financial
instrument leads to an acquisition of shares with voting rights ........................................... 81
Table 4: Triggering event under TD Art. 9(2) ...................................................................... 81
Table 5: Deadline for learning of triggering event under TD Art. 9(1) ................................. 82
Table 6: Deadline for learning of triggering event under TD Art. 9(2) ................................. 82
Table 7: Deadline for making notification to the issuer ....................................................... 83
Table 8: Channels for submitting notifications to NCAs and issuers .................................. 84
Table 9: Permitted formats for submitting notifications to NCAs and issuers ..................... 85
Table 10: Deadline for publishing the notification................................................................ 85
4
Glossary
CEIFs Closed Ended Investment Funds
ESMA European Securities and Markets Authority
L2D Level 2 Directive (Commission Directive 2007/14/EC of 8 March
2007 laying down detailed rules for the implementation of certain
provisions of Directive 2004/109/EC on the harmonisation of
transparency requirements in relation to information about
issuers whose securities are admitted to trading on a regulated
market)
NCA National Competent Authority
Takeover Bids Directive Directive 2004/25/EC of the European Parliament and of the
Council of 21 April 2004 on takeover bids
TD/Transparency Directive Directive 2004/109/EC of the European Parliament and of the
Council of 15 December 2004 on the harmonisation of
transparency requirements in relation to information about
issuers whose securities are admitted to trading on a regulated
market and amending Directive 2001/34/EC including
subsequent amendments.
5
List of country acronyms
AT Austria
BE Belgium
BG Bulgaria
CY Cyprus
CZ Czech Republic
DE Germany
DK Denmark
EE Estonia
EL Greece
ES Spain
FI Finland
FR France
HR Croatia
HU Hungary
IE Ireland
IS Iceland
IT Italy
LT Lithuania
LU Luxembourg
LV Latvia
MT Malta
NL Netherlands
NO Norway
PL Poland
PT Portugal
RO Romania
SE Sweden
SI Slovenia
SK Slovakia
6
Introduction
Reasons for publication
This Practical Guide is an information document which summarises the main rules and
practices applicable across the European Economic Area
1
(EEA) in relation to notifications of
major holdings under national law in accordance with the Transparency Directive. The
Practical Guide is intended as an aide to market participants and may be particularly helpful
to shareholders with notification obligations under national law in accordance with the
Transparency Directive.
Content
Part I of the Practical Guide sets out a summary of the main rules and practices in relation to
making and publishing notifications of major holdings under national law in accordance with
the Transparency Directive. Information is presented on a country-by-country basis to allow
market participants to easily identify information about the jurisdiction(s) of interest to them.
The focus is on on-exchange transactions based on the assumption that these trigger the
majority of notification obligations under the Transparency Directive.
Part II of the Practical Guide presents key data i.e. information on notification thresholds, the
triggering event, the deadline for learning of the triggering event, the deadline for making a
notification as well as permitted channels and format for the filing of such and the deadline for
publishing a notification. Information in Part II is organised in transversal tables, making it
possible to compare rules across different jurisdictions.
Status of information and updates to the Practical Guide
The Practical Guide has been compiled on the basis of information provided by National
Competent Authorities under the Transparency Directive. Any queries regarding Member
State specific content should be addressed directly to the relevant National Competent
Authority in that Member State.
ESMA is responsible only for the accurate reproduction of the information received from the
National Competent Authorities. ESMA does not provide any representation or warranty that
the content of the Practical Guide is complete, accurate or up to date.
ESMA will update the Practical Guide on an ad hoc basis as and when necessary based on
changes to national rules and practices. However, there may be a small delay between the
time at which a change takes place nationally and the time at which the Practical Guide is
amended. If any discrepancy is identified between the information in the Practical Guide and
legislation or rules published by national legislators or National Competent Authorities, priority
should be given to the latter.
The current version of the Practical Guide was published on xx 15 December 2022 and
incorporates changes to information relating to several NCAs
2
.
1
Information about Liechtenstein is not included in this document.
2
AT, BE, CY, CZ, DE, DK, ES, FI, FR, HR, LT, LU, LV, MT, NL, NO, PL, RO and SI.
7
PART I:
COUNTRY-BY-COUNTRY SUMMARY OF NATIONAL
REQUIREMENTS REGARDING NOTIFICATIONS OF MAJOR
HOLDINGS UNDER NATIONAL LAW IN ACCORDANCE
WITH THE TRANSPARENCY DIRECTIVE
Part I of the Practical Guide contains a fact sheet for each country, setting out the national
requirements in relation to notification of major holdings under the Transparency Directive.
The individual fact sheets each have four distinct sections:
• Section A presents general information regarding the competent authority, the
notification thresholds applied in each jurisdiction as well as a hyperlink in case more
information regarding rules on notification of major holdings is required.
• Section B describes the requirements in relation to the notification process, i.e. whether
the use of a standard form is required, the triggering event for on-exchange
transactions and passive crossings, the notification deadline for on-exchange
transactions, the permitted channels and formats for the filing of a notification, whether
notifications are required to be signed as well as the rules on intra-day netting.
• Section C provides information on the entity responsible for publication of a notification
and the deadline for such publication.
• Finally, section D contains a hyperlink to the standard form for the notification of major
holdings if such a standard form is used as well as a hyperlink to the national central
storage mechanism for regulated information (OAM) and contact details for the
National Competent Authority.
8
Austria
National Competent Authority
Financial Market Authority (FMA)
Applicable national notification
thresholds
3
(percentages)
3
4
, 4, 5, 10, 15, 20, 25, 30, 35, 40, 45, 50, 75,
90
For further information, please refer to
https://www.fma.gv.at/en/capital-
markets/disclosure-requirements/major-
holdings/
Standard form
Required (for link please see section D below)
Triggering event
The triggering event is the point in time
at which a shareholder reaches, exceeds
or falls below a notification threshold.
- Triggering event for on-exchange
transactions under TD Art. 9(1) /
Sec. 130 para 1 BörseG
On-exchange transactions are
transactions which are carried
out on a regulated market.
Settlement date
- Triggering event for passive
crossings, i.e. when there is a
change in the breakdown of
voting rights under TD Art. 9(2) /
Sec. 130 para. 2 BörseG
Registration of new shares
Deadline for notifying on-exchange
transactions under TD Art. 12(2) and
L2D Art. 9 / Sec. 130 para. 1 BörseG
The deadline for notifying covers the
maximum permitted time for learning of
the triggering event and for making the
notification.
Two trading days following triggering event
5
3
Furthermore, the thresholds stated by the issuer in its by-laws pursuant to Sec. 27 para. 1 no. 1 of the Austrian Takeover Act
are applicable notification thresholds pursuant to Sec. 130 para. 1 of BörseG as well.
4
In Austria, the threshold of 3% applies only to issuers which have stipulated this threshold value in their articles of association.
A special condition for this to become effective is the publication of the relevant clause of the articles of association on the
issuer’s website and a notification to the FMA.
5
Although the notifiable person shall be deemed to have knowledge of the triggering event no later than two trading days
following the transaction and the deadline for making the notification shall be no later than two further trading days, in general,
the notification shall be submitted promptly but not later than two trading days after the threshold was crossed.
9
Notifying the National Competent
Authority
- Permitted channel(s)
Digital portal (https://www.fma.gv.at/en/capital-
markets/disclosure-requirements/major-
holdings/)
- Permitted format(s)
No rule
Notifying the issuer
- Permitted channel(s)
Email
Fax
Post
- Permitted format(s)
No rule
Signature of notification required when
notification is submitted
To the NCA: No
To the issuer: No
Intra-day netting
Intra-day netting means that a
shareholder who exceeds a notification
threshold and falls below the same
notification threshold later in the same
trading day nets the voting rights for the
calculation of the notification position.
Permitted
Entity responsible for publishing
notifications under TD Art. 12 / Sec. 135
para. 2 BörseG
Issuer
Deadline for publication after the date of
receipt of the notification
Two trading days after the date of receipt of
the notification
Link to standard form (if applicable)
https://www.fma.gv.at/en/capital-
markets/disclosure-requirements/major-
holdings/
Link to national central storage
mechanism for regulated information
(OAM)
http://issuerinfo.oekb.at/startpage.html
Contact details for National Competent
Authority if further information is needed
marktaufsicht@fma.gv.at
10
Belgium
National Competent Authority
Financial Services and Markets Authority
(FSMA)
Applicable national notification
thresholds (percentages)
5, 10, 15, 20, 25, 30, 35, 40, 45, 50, 55, 60,
65, 70, 75, 80, 85, 90, 95
For further information, please refer to
https://www.fsma.be/en/shareholding-
structure-0
Standard form
Optional but in practice always used
Triggering event
The triggering event is the point in time
at which a shareholder reaches, exceeds
or falls below a notification threshold.
- Triggering event for on-exchange
transactions under TD Art. 9(1) /
Art. 8, 1° Law of 2 May 2007
On-exchange transactions are
transactions which are carried
out on a regulated market.
Trade date
- Triggering event for passive
crossings, i.e. when there is a
change in the breakdown of
voting rights under TD Art. 9(2) /
Art. 8, 3° Law of 2 May 2007
Registration of new shares
Deadline for notifying on-exchange
transactions under TD Art. 12(2) and
L2D Art. 9 / Art. 12, 1° Law of 2 May
2007 and Art. 5 RD of 14 February 2008
The deadline for notifying covers the
maximum permitted time for learning of
the triggering event and for making the
notification.
Six trading days following triggering event
Notifying the National Competent
Authority
- Permitted channel(s)
Email (trp.fin@fsma.be)
- Permitted format(s)
Excel
Readable PDF
11
Notifying the issuer
- Permitted channel(s)
Email
- Permitted format(s)
Readable PDF
Signature of notification required when
notification is submitted
To the NCA: Yes
To the issuer: Yes
Intra-day netting
Intra-day netting means that a
shareholder who exceeds a notification
threshold and falls below the same
notification threshold later in the same
trading day nets the voting rights for the
calculation of the notification position.
Permitted
Entity responsible for publishing
notifications under TD Art. 12 / Art. 14
Law of 2 May 2007
Issuer
Deadline for publication after the date of
receipt of notification
Three trading days after the day on which the
notification was received
Link to standard form (if applicable)
https://www.fsma.be/sites/default/files/media/fil
es/replacement_files/tr-1be-en.xlsm
Link to national central storage
mechanism for regulated information
(OAM)
http://stori.fsma.be/Pages/Search.aspx?PageI
D=f3b9f276-36ab-42ae-9c7d-7b29492756f5
Contact details for National Competent
Authority if further information is needed
trp.fin@fsma.be
12
Bulgaria
National Competent Authority
Financial Supervision Commission (FSC)
Applicable national notification
thresholds (percentages)
5, 10, 15, 20, 25, 30, 35, 40, 45, 50, 55, 60,
65, 70, 75, 80, 85, 90, 95
For further information, please refer to
http://www.fsc.bg/en/markets/capital-
market/legal-framework/laws/
6
Standard form
Required (for link please see section D below)
Triggering event
The triggering event is the point in time
at which a shareholder reaches, exceeds
or falls below a notification threshold.
- Triggering event for on-exchange
transactions under TD Art. 9(1) /
Article 145 and following of
Public Offering of Securities Act
in conjunction with article 127
par. 2 of Rules of procedure of
Central Depository AD
On-exchange transactions are
transactions which are carried
out on a regulated market.
Settlement date
- Triggering event for passive
crossings, i.e. when there is a
change in the breakdown of
voting rights under TD Art. 9(2) /
Article 127 par. 1 of Public
Offering of Securities Act in
conjunction with article 110 of
Rules of procedure of Central
Depository AD
Registration of new shares
Deadline for notifying on-exchange
transactions under TD Art. 12(2) and
L2D Art. 9 / Article 148 par. 3 of Public
Offering of Securities Act
The deadline for notifying covers the
maximum permitted time for learning of
the triggering event and for making the
notification.
Six trading days following triggering event
6
Article 145 and following of Public Offering of Securities Act.
13
Notifying the National Competent
Authority
- Permitted channel(s)
Email
(delovodstv[email protected];
bg_fsc@fsc.bg)
Fax (+35928294324)
Post (1000 Sofia, 16
Budapeshta str.,
Bulgaria)
- Permitted format(s)
Word
Notifying the issuer
- Permitted channel(s)
Email
Fax
Post
- Permitted format(s)
Word
Signature of notification required when
notification is submitted
To the NCA: Yes
To the issuer: Yes
Intra-day netting
Intra-day netting means that a
shareholder who exceeds a notification
threshold and falls below the same
notification threshold later in the same
trading day nets the voting rights for the
calculation of the notification position.
Not permitted
Entity responsible for publishing
notifications under TD Art. 12 / Article
148b of Public Offering of Securities Act
Issuer
Deadline for publication after the date of
receipt of notification
Three trading days after the day on which the
notification was received
Link to standard form (if applicable)
http://www.fsc.bg/en/administrative-
documents/template
Link to national central storage
mechanism for regulated information
(OAM)
http://www3.fsc.bg/eregnews/index.jsp?action
Contact details for National Competent
Authority if further information is needed
alexov[email protected]
14
Croatia
National Competent Authority
Croatian Financial Services Supervisory
Agency (HANFA)
Applicable national notification
thresholds (percentages)
5, 10, 15, 20, 25, 30, 50, 75
For further information, please refer to
http://www.hanfa.hr/EN/nav/189/capital-
market-act-.html
7
Standard form
No standard form
For the content of the notification please see
Article 486 of the Capital Market Act
Triggering event
The triggering event is the point in time
at which a shareholder reaches, exceeds
or falls below a notification threshold.
- Triggering event for on-exchange
transactions under TD Art. 9(1) /
Article 482 paragraph 2 point 1
and Article 487 of the Capital
Market Act
On-exchange transactions are
transactions which are carried
out on a regulated market.
Trade date
- Triggering event for passive
crossings, i.e. when there is a
change in the breakdown of
voting rights under TD Art. 9(2) /
Article 482 paragraph 2 point 2
and Article 487 of the Capital
Market Act
Publication under TD Art. 15 / Article 473 of
the Capital Market Act
− Deadline for publication under TD
Art. 15
End of month
7
Articles 472 to 499 of the Capital Market Act.
15
Deadline for notifying on-exchange
transactions under TD Art. 12(2) and
L2D Art. 9 / Article 487 of the Croatian
Capital Market Act
The deadline for notifying covers the
maximum permitted time for learning of
the triggering event and for making the
notification.
Four trading days following triggering event
Notifying the National Competent
Authority
- Permitted channel(s)
Post (Franje Račkoga 6, 10000 Zagreb,
Croatia)
- Permitted format(s)
No rule
Notifying the issuer
- Permitted channel(s)
No rule
- Permitted format(s)
No rule
Signature of notification required when
notification is submitted
To the NCA: Yes
To the issuer: Yes
Intra-day netting
Intra-day netting means that a
shareholder who exceeds a notification
threshold and falls below the same
notification threshold later in the same
trading day nets the voting rights for the
calculation of the notification position.
Not permitted
Entity responsible for publishing
notifications under TD Art. 12 / Article
472 of the Capital Market Act
Issuer
Deadline for publication after the date of
receipt of notification
Two trading days after the day on which the
notification was received
Link to standard form (if applicable)
Not applicable
Link to national central storage
mechanism for regulated information
(OAM)
http://www.hanfa.hr/srpi.html
Contact details for National Competent
Authority if further information is needed
transparentnost@hanfa.hr
16
Cyprus
National Competent Authority
Cyprus Securities and Exchange Commission
(CySEC)
Applicable national notification
thresholds (percentages)
5, 10, 15, 20, 25, 30, 50, 75
For further information, please refer to
http://www.cysec.gov.cy/en-
GB/legislation/issuers/TRANSPARENCY/
Standard form
Required (for link please see section D below)
Triggering event
The triggering event is the point in time
at which a shareholder reaches, exceeds
or falls below a notification threshold.
- Triggering event for on-exchange
transactions under TD Art. 9(1) /
Article 33(1)(a)(i) of the
Transparency Requirements
(Securities Admitted to Trading
on a Regulated Market) Law of
2007, L.190(I)/2007, as amended
(‘Transparency Law’)
On-exchange transactions are
transactions which are carried
out on a regulated market.
Trade date
- Triggering event for passive
crossings, i.e. when there is a
change in the breakdown of
voting rights under TD Art. 9(2) /
Article 28(3) of the Transparency
Law
Publication under TD Art. 15 / Article 18 of the
Transparency Law
− Deadline for publication under TD
Art. 15
End of month
Deadline for notifying on-exchange
transactions under TD Art. 12(2) and
L2D Art. 9 / Articles 33(1) and 33(2) of
the Transparency Law
The deadline for notifying covers the
maximum permitted time for learning of
the triggering event and for making the
notification.
Five trading days following triggering event
17
Notifying the National Competent
Authority
- Permitted channel(s)
Email
issuers@cysec.gov.cy
Fax (+35722506700)
Post (19 Diagorou
Street, 1097 Nicosia,
Cyprus;
P.O BOX 24996
1306 Nicosia, Cyprus)
- Permitted format(s)
No rule
Notifying the issuer
- Permitted channel(s)
No rule
- Permitted format(s)
No rule
Signature of notification required when
notification is submitted
To the NCA: Yes
To the issuer: Yes
Intra-day netting
Intra-day netting means that a
shareholder who exceeds a notification
threshold and falls below the same
notification threshold later in the same
trading day nets the voting rights for the
calculation of the notification position.
Permitted
Entity responsible for publishing
notifications under TD Art. 12 / Article 19
of the Transparency Law
Issuer
Deadline for publication after the date of
receipt of notification
On the trading day after the day on which the
notification was received
Link to standard form (if applicable)
http://www.cysec.gov.cy/en-
GB/legislation/issuers/TRANSPARENCY/#
Link to national central storage
mechanism for regulated information
(OAM)
http://oam.cse.com.cy/Announcement/Search
Contact details for National Competent
Authority if further information is needed
issuers@cysec.gov.cy
For the attention of the Issuers Department
18
Czech Republic
National Competent Authority
Czech National Bank
Applicable national notification
thresholds (percentages)
1
8
, 3
9
, 5, 10, 15, 20, 25, 30, 40, 50, 75
For further information, please refer to
https://www.cnb.cz/en/supervision-financial-
market/conduct-of-supervision/information-
duties-of-financial-market-entities-vis-a-vis-the-
czech-national-bank/regular-reporting-of-
issuers-and-other-persons/
Standard form
Required (for link please see section D below)
Triggering event
The triggering event is the point in time
at which a shareholder reaches, exceeds
or falls below a notification threshold.
- Triggering event for on-exchange
transactions under TD Art. 9(1) /
Capital Market Undertakings Act
No 256/2004 Coll., Section
122(1)
On-exchange transactions are
transactions which are carried
out on a regulated market.
Settlement date
- Triggering event for passive
crossings, i.e. when there is a
change in the breakdown of
voting rights under TD Art. 9(2) /
Capital Market Undertakings Act
No 256/2004 Coll., Section
122a(1)
For capital decreases: The registration date in
the company register
For capital increases: The date determined by
the issuer at the shareholders’ meeting which
will be not prior to the exercise of subscription
rights and not later than on the registration
date in the company register
Deadline for notifying on-exchange
transactions under TD Art. 12(2) and
L2D Art. 9 / Capital Market Undertakings
Act No 256/2004 Coll., Section 122(4)
The deadline for notifying covers the
maximum permitted time for learning of
the triggering event and for making the
notification.
Six trading days following triggering event
8
The 1% threshold only applies to holdings in companies with share capital > 500m CZK.
9
The 3% threshold only applies to holdings in companies with share capital > 100m CZK.
19
Notifying the National Competent
Authority
- Permitted channel(s)
Digital portal
(http://www.cnb.cz/cn
b/sipres_en)
Post (Česká národní
banka, Senovážná 3,
115 03 Praha 1)
- Permitted format(s)
Word
Readable PDF
Notifying the issuer
- Permitted channel(s)
No rule
- Permitted format(s)
Word
Readable PDF
Signature of notification required when
notification is submitted
To the NCA: Yes
To the issuer: No
Intra-day netting
Intra-day netting means that a
shareholder who exceeds a notification
threshold and falls below the same
notification threshold later in the same
trading day nets the voting rights for the
calculation of the notification position.
Permitted
Entity responsible for publishing
notifications under TD Art. 12 / Capital
Market Undertakings Act No 256/2004
Coll., Section 122(7)
National Competent Authority
Deadline for publication after the date of
receipt of notification
Three trading days after the day on which the
notification was received
Link to standard form (if applicable)
https://www.cnb.cz/export/sites/cnb/en/supervi
sion-financial-
market/.galleries/conduct_of_supervision/infor
mation_duties/issuers_other_entities/download
/form_for_notification_of_major_holdings_tem
plate_7.docx
Link to national central storage
mechanism for regulated information
(OAM)
https://www.cnb.cz/cnb/oam_en
Contact details for National Competent
Authority if further information is needed
podateln[email protected]
20
Denmark
National Competent Authority
The Danish FSA
Applicable national notification
thresholds (percentages)
5, 10, 15, 20, 25, 1/3, 50, 2/3, 90
For further information, please
refer to
https://www.finanstilsynet.dk/Lovgivning/Information-
om-udvalgte-tilsynsomraader/Storaktionaerer
Standard form
Required (for link please see section D below)
Triggering event
The triggering event is the point in
time at which a shareholder
reaches, exceeds or falls below a
notification threshold.
- Triggering event for on-
exchange transactions
under TD Art. 9(1) / section
29(1) of the Securities
Trading etc. Act.
10
On-exchange transactions
are transactions which are
carried out on a regulated
market.
Trade date
- Triggering event for
passive crossings, i.e.
when there is a change in
the breakdown of voting
rights under TD Art. 9(2) /
section 29(1) of the
Securities Trading etc.
Act.
11
Publication under TD Art. 15 / section 10 of the
executive order on issuers’ duty to provide
information
− Deadline for publication
under TD Art. 15
End of month
10
From 1 January 2018, section 38-40 of the Capital market Act.
11
From 1 January 2018, section 38-40 of the Capital market Act.
21
Deadline for notifying on-
exchange transactions under TD
Art. 12(2) and L2D Art. 9 / section
29(1) of the Securities Trading
etc. Act. and section 3(1) of the
Executive Order on Major
Shareholder
The deadline for notifying covers
the maximum permitted time for
learning of the triggering event
and for making the notification.
Same trading day as triggering event
12
Notifying the National Competent
Authority
- Permitted channel(s)
Digital portal (https://oam.finanstilsynet.dk/#!/)
- Permitted format(s)
No rule
Notifying the issuer
- Permitted channel(s)
No rule
- Permitted format(s)
No rule
Signature of notification required
when notification is submitted
To the NCA: Yes
To the issuer: No
Intra-day netting
Intra-day netting means that a
shareholder who exceeds a
notification threshold and falls
below the same notification
threshold later in the same
trading day nets the voting rights
for the calculation of the
notification position.
Not permitted
13
Entity responsible for publishing
notifications under TD Art. 12 /
section 29(1) of the Securities
Trading etc. Act and section 3 of
the Executive Order on Major
Shareholder
Issuer
Deadline for publication after the
date of receipt of notification
On the day on which the notification was received
14
12
From 1 January 2018, the deadline for notifying on-exchange transactions under TD Art. 12(2) and L2D Art. 9 will be four
trading days after learning (section 41 of the Capital Market act).
13
Permitted from 1 January 2018.
14
From 1 January 2018, the deadline for publication will be three days after the notification was received.
22
Link to standard form (if
applicable)
https://www.finanstilsynet.dk/Lovgivning/Information-
om-udvalgte-
tilsynsomraader/Storaktionaerer/Indberetning
Link to national central storage
mechanism for regulated
information (OAM)
https://oam.finanstilsynet.dk/#!/
Contact details for National
Competent Authority if further
information is needed
pbu@ftnet.dk
23
Estonia
National Competent Authority
Finantsinspektsioon
Applicable national notification
thresholds (percentages)
5, 10, 15, 20, 25, 1/3, 50, 2/3
For further information, please refer to
http://www.fi.ee/index.php?id=11886
Standard form
Optional (the use of the standard form is not
obligatory, but recommended)
Triggering event
The triggering event is the point in time
at which a shareholder reaches, exceeds
or falls below a notification threshold.
- Triggering event for on-exchange
transactions under TD Art. 9(1) /
Securities Market Act § 185(1)
On-exchange transactions are
transactions which are carried
out on a regulated market.
Trade date
- Triggering event for passive
crossings, i.e. when there is a
change in the breakdown of
voting rights under TD Art. 9(2) /
Securities Market Act § 185(2)
Publication under TD Art. 15 / Securities
Market Act § 187-5
− Deadline for publication under TD
Art. 15
The issuer is required to publish any changes
in the total number of voting rights and the size
of the capital promptly
Deadline for notifying on-exchange
transactions under TD Art. 12(2) and
L2D Art. 9 / Securities Market Act § 185-
2
The deadline for notifying covers the
maximum permitted time for learning of
the triggering event and for making the
notification.
Six trading days following triggering event
24
Notifying the National Competent
Authority
- Permitted channel(s)
Email (info@fi.ee)
Fax (+3726680501)
Post
(Finantsinspektsioon,
Sakala 4, 15030
Tallinn, Estonia)
- Permitted format(s)
No rule
Notifying the issuer
- Permitted channel(s)
No rule
- Permitted format(s)
No rule
Signature of notification required when
notification is submitted
To the NCA: Yes
To the issuer: Yes
Intra-day netting
Intra-day netting means that a
shareholder who exceeds a notification
threshold and falls below the same
notification threshold later in the same
trading day nets the voting rights for the
calculation of the notification position.
Not permitted
Entity responsible for publishing
notifications under TD Art. 12 / Securities
Market Act § 186
Issuer
Deadline for publication after the date of
receipt of notification
Three trading days after the day on which the
notification was received
Link to standard form (if applicable)
http://www.fi.ee/index.php?id=11886
Link to national central storage
mechanism for regulated information
(OAM)
http://oam.fi.ee/et/home;jsessionid=3BE72917
B0D1808D4D70A88D0E9019FA
Contact details for National Competent
Authority if further information is needed
info@fi.ee
25
Finland
National Competent Authority
Finanssivalvonta (FIN-FSA)
Applicable national notification
thresholds (percentages)
5, 10, 15, 20, 25, 30, 50, 2/3, 90 (shares and
voting rights)
For further information, please refer to
Notification of major holdings - Issuers and
investors - www.finanssivalvonta.fi
Standard form
Optional (The notification should be made in
writing on the notification form. However, other
formats are also allowed.)
Triggering event
The triggering event is the point in time
at which a shareholder reaches, exceeds
or falls below a notification threshold.
- Triggering event for on-exchange
transactions under TD Art. 9(1) /
the Securities Markets Act,
chapter 9, section 5
On-exchange transactions are
transactions which are carried
out on a regulated market.
Trade date
- Triggering event for passive
crossings, i.e. when there is a
change in the breakdown of
voting rights under TD Art. 9(2) /
the Securities Markets Act,
chapter 9, section 5
Publication under TD Art. 15 / the Securities
Markets Act, chapter 8, section 6
− Deadline for publication under TD
Art. 15 publication
End of month
Deadline for notifying on-exchange
transactions under TD Art. 12(2) and
L2D Art. 9 / the Securities Markets Act,
chapter 9, section 9
The deadline for notifying covers the
maximum permitted time for learning of
the triggering event and for making the
notification.
Three trading days following triggering event
26
Notifying the National Competent
Authority
- Permitted channel(s)
Email (kirjaamo@finanssivalvonta.fi)
- Permitted format(s)
No rule
Notifying the issuer
- Permitted channel(s)
No rule
- Permitted format(s)
No rule
Signature of notification required when
notification is submitted
To the NCA: No
To the issuer: No
Intra-day netting
Intra-day netting means that a
shareholder who exceeds a notification
threshold and falls below the same
notification threshold later in the same
trading day nets the voting rights for the
calculation of the notification position.
Permitted
Entity responsible for publishing
notifications under TD Art. 12 / the
Securities Markets Act, chapter 9,
section 10
Issuer
Deadline for publication after the date of
receipt of notification
Publication of the notification should be made
as soon as possible; this will in most cases be
on the day when the notification was made but
the issuer may delay publication in order to
receive corrected or supplementary
information in relation to the notification
Link to standard form (if applicable)
Notification of major holdings - Issuers and
investors - www.finanssivalvonta.fi
Link to national central storage
mechanism for regulated information
(OAM)
https://csf.omxgroup.com/cns-
web/oam/Search.action?request_locale=fi
Contact details for National Competent
Authority if further information is needed
Ms Marianne Demecs, Senior Market
Supervisor, tel. +358 9 183 5366
Ms Anna Sahrakorpi, Market Supervisor, tel.
+358 9 183 5458
Mr Rickard Sandell, Market Supervisor, tel.
+358 9 183 5353
27
France
National Competent Authority
Autorité des marchés financiers (AMF)
Applicable national notification
thresholds (percentages)
5, 10, 15, 20, 25, 30, 1/3, 50, 2/3, 90, 95
For further information, please refer to
https://www.amf-
france.org/en/professionals/professional-
investor/my-relations-amf/major-holding
Standard form
Required (for link please see section D below)
Triggering event
The triggering event is the point in time
at which a shareholder reaches, exceeds
or falls below a notification threshold.
- Triggering event for on-exchange
transactions under TD Art. 9(1) /
Article 233-7 of the French
Commercial Code
On-exchange transactions are
transactions which are carried
out on a regulated market.
Trade date
- Triggering event for passive
crossings, i.e. when there is a
change in the breakdown of
voting rights under TD Art. 9(2) /
Article 233-7 of the French
Commercial Code
Settlement date
Deadline for notifying on-exchange
transactions under TD Art. 12(2) and
L2D Art. 9 / Article 233-7 of the French
Commercial Code
The deadline for notifying covers the
maximum permitted time for learning of
the triggering event and for making the
notification.
Four trading days following triggering event
28
Notifying the National Competent
Authority
- Permitted channel(s)
Email
(declarationseuil@am
f-france.org)
Fax (+0033(0)15345-
6250)
Post (17, place de la
bourse, 75082 Paris
Cedex 02)
- Permitted format(s)
Word
Readable PDF
Notifying the issuer
- Permitted channel(s)
No rule
- Permitted format(s)
Word
Readable PDF
Signature of notification required when
notification is submitted
To the NCA: Yes
To the issuer: Yes
Intra-day netting
Intra-day netting means that a
shareholder who exceeds a notification
threshold and falls below the same
notification threshold later in the same
trading day nets the voting rights for the
calculation of the notification position.
Permitted
Entity responsible for publishing
notifications under TD Art. 12 / Article
233-7 of the French Commercial Code
National Competent Authority
Deadline for publication after the date of
receipt of notification
Three trading days after the day on which the
notification was received
Link to standard form (if applicable)
https://www.amf-france.org/en/forms-and-
declarations/listed-companies-and-corporate-
financing/major-holding-notifications-intentions
Link to national central storage
mechanism for regulated information
(OAM)
http://www.info-financiere.fr/
29
Contact details for National Competent
Authority if further information is needed
Autorité des marchés financiers - AMF
Direction des Emetteurs
17, place de la bourse
75082 PARIS Cedex 02
E-mail: declarationseuil@amf-france.org
Tel.: +00 33 (0)1 5345-6280
Fax: +00 33 (0)1 5345-6268
30
Germany
National Competent Authority
Bundesanstalt für
Finanzdienstleistungsaufsicht - BaFin (Federal
Financial Supervisory Authority)
Applicable national notification
thresholds (percentages)
3
15
, 5, 10, 15, 20, 25, 30, 50, 75
For further information, please refer to
www.bafin.de (also available in English)
Standard form
Required (for link please see section D below)
Triggering event
The triggering event is the point in time
at which a shareholder reaches, exceeds
or falls below a notification threshold.
- Triggering event for on-exchange
transactions under TD Art. 9(1) /
§ 21 WpHG
On-exchange transactions are
transactions which are carried
out on a regulated market.
Trade date
- Triggering event for passive
crossings, i.e. when there is a
change in the breakdown of
voting rights under TD Art. 9(2) /
§ 21 WpHG
Registration of new shares
Deadline for notifying on-exchange
transactions under TD Art. 12(2) and
L2D Art. 9 / § 21 WpHG
The deadline for notifying covers the
maximum permitted time for learning of
the triggering event and for making the
notification.
Four
16
trading days following triggering event
15
The 3% threshold applies only for notifying voting rights (TD Art. 9/10), but not for positions arising out of financial
instruments (TD Art. 13) or aggregated positions (TD Art. 13a).
16
Although the legal provisions provide for two plus four trading days, in practice the disclosure of a notification to BaFin and to
the issuer is generally expected within four trading days irrespectively of the composition of this deadline. Only in very
extraordinary cases may the maximum deadline of six trading days apply.
31
Notifying the National Competent
Authority
- Permitted channels
- Permitted format(s)
BAFIN’s MVP-portal
Online form or upload of defined xml-file
Notifying the issuer
- Permitted channels
- Permitted format(s)
Email
Readable format (e.g. pdf) and defined xml-file
(as footnote: Both files get provided by BaFin’s
system after having filed in BaFin’s MVP-
portal.)
Signature of notification required when
notification is submitted
To the NCA: No
To the issuer: No
Intra-day netting
Intra-day netting means that a
shareholder who exceeds a notification
threshold and falls below the same
notification threshold later in the same
trading day nets the voting rights for the
calculation of the notification position.
Permitted (only if voting rights do not get
exercised on the day of transactions)
Entity responsible for publishing
notifications under TD Art. 12 / § 26
WpHG
Issuer
Deadline for publication after the date of
receipt of notification
Three trading days after the day on which the
notification was received
Link to standard form (if applicable)
https://www.bafin.de/EN/Aufsicht/BoersenMaer
kte/Transparenz/Informationspflichten_fuer_E
mittenten/BedeutendeStimmrechtsanteile/bede
utendestimmrechtsanteile_node_en.html
Link to national central storage
mechanism for regulated information
(OAM)
https://www.unternehmensregister.de/ureg/
Contact details for National Competent
Authority if further information is needed
wa22marktueberwachung@bafin.de
32
Greece
National Competent Authority
Hellenic Capital Market Commission
Applicable national notification
thresholds (percentages)
5, 10, 15, 20, 25, 1/3, 50, 2/3 as well as any
change equal to or greater than +/- 3% over
the 10% threshold
For further information, please refer to
http://www.hcmc.gr/el/ypochreoseis-diarkous-
plerophoreses-tou-ependytikou-koinou
Standard form
Required (for link please see section D below)
Triggering event
The triggering event is the point in time
at which a shareholder reaches, exceeds
or falls below a notification threshold.
- Triggering event for on-exchange
transactions under TD Art. 9(1) /
HCMC Circ. 33/2007
On-exchange transactions are
transactions which are carried
out on a regulated market.
Trade date
- Triggering event for passive
crossings, i.e. when there is a
change in the breakdown of
voting rights under TD Art. 9(2) /
HCMC Circ. 33/2007
Start of trading of shares
Deadline for notifying on-exchange
transactions under TD Art. 12(2) and
L2D Art. 9 / par. 2, art. 14, L.3556/2007
The deadline for notifying covers the
maximum permitted time for learning of
the triggering event and for making the
notification.
Three trading days following triggering event
Notifying the National Competent
Authority
- Permitted channel(s)
Email
([email protected])
Fax (+302103377243)
Post (Kolokotroni 1
St., Athens 10562,
Greece)
- Permitted format(s)
No rule
33
Notifying the issuer
- Permitted channel(s)
No rule
- Permitted format(s)
No rule
Signature of notification required when
notification is submitted
To the NCA: Yes
To the issuer: Yes
Intra-day netting
Intra-day netting means that a
shareholder who exceeds a notification
threshold and falls below the same
notification threshold later in the same
trading day nets the voting rights for the
calculation of the notification position.
Permitted
17
Entity responsible for publishing
notifications under TD Art. 12 / par. 3,
art. 14, L.3556/2007
Issuer
Deadline for publication after the date of
receipt of notification
Two trading days after the day on which the
notification was received
Link to standard form (if applicable)
http://www.hcmc.gr/aweb/files/dposlc/files/For
m%20for%20notification%20of%20major%20h
oldings.pdf
Link to national central storage
mechanism for regulated information
(OAM)
http://www.helex.gr/
Contact details for National Competent
Authority if further information is needed
tr1@cmc.gov.gr
17
HCMC Circ. 33/2007
34
Hungary
National Competent Authority
The Central Bank of Hungary
Applicable national notification
thresholds (percentages)
5, 10, 15, 20, 25, 30, 35, 40, 45, 50, 75, 80,
85, 90, 91, 92, 93, 94, 95, 96, 97, 98, 99
For further information, please refer to
www.mnb.hu
Standard form
Required
Triggering event
The triggering event is the point in time
at which a shareholder reaches, exceeds
or falls below a notification threshold.
- Triggering event for on-exchange
transactions under TD Art. 9(1) /
Article 61 (1) item a of the Act
CXX of 2001 on the Capital
Markets, in case of own shares it
is the issuer’s obligation under
Article 61 (2) of the Act CXX of
2001 on the Capital Markets
On-exchange transactions are
transactions which are carried
out on a regulated market.
Trade date
- Triggering event for passive
crossings, i.e. when there is a
change in the breakdown of
voting rights under TD Art. 9(2) /
Article 61 (1) item b of the Act
CXX of 2001 on the Capital
Markets, in case of own shares it
is the issuer’s obligation under
Article 61 (2) of the Act CXX of
2001 on the Capital Markets
Registration of new shares
Deadline for notifying on-exchange
transactions under TD Art. 12(2) and
L2D Art. 9 / Article 61 (1) of the Act CXX
of 2001 on the Capital Markets
The deadline for notifying covers the
maximum permitted time for learning of
the triggering event and for making the
notification.
Two calendar days following triggering event
35
Notifying the National Competent
Authority
- Permitted channel(s)
Digital portal
18
- Permitted format(s)
No rule
Notifying the issuer
- Permitted channel(s)
No rule
- Permitted format(s)
No rule
Signature of notification required when
notification is submitted
To the NCA
Yes
To the issuer
No
Intra-day netting
Intra-day netting means that a
shareholder who exceeds a notification
threshold and falls below the same
notification threshold later in the same
trading day nets the voting rights for the
calculation of the notification position.
Permitted
Entity responsible for publishing
notifications under TD Art. 12 / Article 55
(2) of the Act CXX of 2001 on the Capital
Markets
Issuer
Deadline for publication after the date of
receipt of notification
Two calendar days after the day on which the
notification was received
Link to standard form (if applicable)
Not available
19
Link to national central storage
mechanism for regulated information
(OAM)
https://kozzetetelek.mnb.hu/en
Contact details for National Competent
Authority if further information is needed
Dr. Adrienne László
Email: laszload@mnb.hu
Tel.: +36-1-489-9653
18
Only registered users are provided access to the digital portal. Investors have to nominate a natural person (employee, legal
representative etc.) to act on their behalf as administrator of the filing of regulated information to the national competent
authority. For more information, please see here:
https://era.mnb.hu/data/cms2421746/Regisztracios_folyamat_Felhasznaloi_Kezikonyv_20141124.pdf.
19
The link to the standard form is available only to registered users of the digital portal.
36
Iceland
National Competent Authority
Central Bank of Iceland
Applicable national notification
thresholds (percentages)
5, 10, 15, 20, 25, 30, 35, 40, 50, 2/3, 90
For further information, please refer to
https://en.fme.is/
Standard form
Required (for link please see section D below)
Triggering event
The triggering event is the point in time
at which a shareholder reaches, exceeds
or falls below a notification threshold.
- Triggering event for on-exchange
transactions under TD Art. 9(1) /
Article 12(1) of Act No. 20/2021
on transparency of issuers and
major holding notifications
On-exchange transactions are
transactions which are carried
out on a regulated market.
Trade date
- Triggering event for passive
crossings, i.e. when there is a
change in the breakdown of
voting rights under TD Art. 9(2) /
Article 12(2) of Act No. 20/2021
on transparency of issuers and
major holding notifications
Publication of the results of the share capital
increase
Deadline for notifying on-exchange
transactions under TD Art. 12(2) and
L2D Art. 9 / Article 21 of Act No. 20/2021
on transparency of issuers and major
holding notifications
The deadline for notifying covers the
maximum permitted time for learning of
the triggering event and for making the
notification.
Four trading days following triggering event
Notifying the National Competent
Authority
- Permitted channel(s)
• Email (sedlabanki@sedlabanki.is)
- Permitted format(s)
No rule
37
Notifying the issuer
- Permitted channel(s)
No rule
- Permitted format(s)
No rule
Signature of notification required when
notification is submitted
To the NCA: Yes
To the issuer: Yes
Intra-day netting
Intra-day netting means that a
shareholder who exceeds a notification
threshold and falls below the same
notification threshold later in the same
trading day nets the voting rights for the
calculation of the notification position.
Permitted
Entity responsible for publishing
notifications under TD Art. 12 / Article 22
of Act No. 20/2021 on transparency of
issuers and major holding notifications
Issuer
Deadline for publication after the date of
receipt of notification
Three trading days after the day on which the
notification was received
Link to standard form (if applicable)
https://en.fme.is/supervision/oam/
Link to national central storage
mechanism for regulated information
(OAM)
www.oam.is
Contact details for National Competent
Authority if further information is needed
• sedlabanki@sedlabanki.is
• fina[email protected]
38
Ireland
National Competent Authority
Central Bank of Ireland
Applicable national notification
thresholds (percentages)
For closed-ended collective investment
schemes and non-Irish issuers: 5, 10, 15, 20,
25, 30, 50, 75
For all other issuers: 3% and each 1%
thereafter up to 100%
For further information, please refer to
http://www.centralbank.ie/regulation/securities-
markets/transparency/Pages/default.aspx
Standard form
Required (for link please see section D below)
Triggering event
The triggering event is the point in time
at which a shareholder reaches, exceeds
or falls below a notification threshold.
- Triggering event for on-exchange
transactions under TD Art. 9(1) /
See also Part 5 of the
Transparency Directive
(2004/109/EC) Regulations 2007
as amended (the “Regulations”),
and Part 7 of the Central Bank of
Ireland’s Transparency Rules
On-exchange transactions are
transactions which are carried
out on a regulated market.
Trade date
- Triggering event for passive
crossings, i.e. when there is a
change in the breakdown of
voting rights under TD Art. 9(2) /
See also Part 5 of the
Regulations, and guidance
provided in Form TR1 (for link
please see section D below)
Publication under TD Art. 15 / See also
Regulation 20 of the Regulations
− Deadline for publication under TD
Art. 15
End of month
39
Deadline for notifying on-exchange
transactions under TD Art. 12(2) and
L2D Art. 9 / See also Part 5 of the
Regulations, and Part 7 of the Central
Bank of Ireland’s Transparency Rules
The deadline for notifying covers the
maximum permitted time for learning of
the triggering event and for making the
notification.
For closed-ended collective investment
schemes and non-Irish issuers: Six trading
days following triggering event
For all other issuers: Four trading days
following triggering event
Notifying the National Competent
Authority
- Permitted channel(s)
Email (tr1shareholder@corporatefinance-cbi.ie
/ tr1issuer@corporatefinance-cbi.ie as
applicable)
- Permitted format(s)
No rule
Notifying the issuer
- Permitted channel(s)
No rule
- Permitted format(s)
No rule
Signature of notification required when
notification is submitted
To the NCA: No
To the issuer: No
Intra-day netting
Intra-day netting means that a
shareholder who exceeds a notification
threshold and falls below the same
notification threshold later in the same
trading day nets the voting rights for the
calculation of the notification position.
Permitted (see also Part 7 of the Central Bank
of Ireland’s Transparency Rules)
Entity responsible for publishing
notifications under TD Art. 12 / See also
Part 5 of the Regulations, and Part 7 of
the Central Bank of Ireland’s
Transparency Rules
Issuer
Deadline for publication after the date of
receipt of notification
For closed-ended collective investment
schemes and non-Irish issuers: Three trading
days after the day on which the notification
was received
For all other issuers: Trading day after the day
on which the notification was received
40
Link to standard form (if applicable)
http://www.centralbank.ie/regulation/securities-
markets/transparency/Pages/forms.aspx
Link to national central storage
mechanism for regulated information
(OAM)
http://www.ise.ie/Market-Data-
Announcements/Announcements/
Contact details for National Competent
Authority if further information is needed
regulateddisclosures@centralbank.ie
41
Italy
National Competent Authority
Commissione Nazionale per le Società e la
Borsa (Consob)
Applicable national notification
thresholds (percentages)
3
20
, 5, 10
21
, 15, 20
21
, 25
21
, 30, 50, 2/3, 90
For further information, please refer to
http://www.consob.it/mainen/documenti/englis
h/laws/reg11971e.htm#Article_117
Standard form
Required (for link please see section D below)
Triggering event
The triggering event is the point in time
at which a shareholder reaches, exceeds
or falls below a notification threshold.
- Triggering event for on-exchange
transactions under TD Art. 9(1) /
Art. 121, paragraph 1, of the
Issuers’ Regulation no. 11971 of
14 May 1999
On-exchange transactions are
transactions which are carried
out on a regulated market.
Trade date
- Triggering event for passive
crossings, i.e. when there is a
change in the breakdown of
voting rights under TD Art. 9(2) /
Articles 121, paragraph 1, and
117, paragraph 2, of the Issuers’
Regulation no. 11971 of 14 May
1999
Publication under TD Art. 15
22
/ Art. 85-bis,
paragraphs 1 and 2, of the Issuers’ Regulation
no. 11971 of 14 May 1999
− Deadline for publication under TD
Art. 15
Day after deposit to the public register (except
specific cases
23
)
20
This threshold is only applicable to non-SME companies.
21
A declaration of intent, i.e. a statement of investment objectives, will be required when the 10%, 20%, and 25% threshold is
exceeded.
22
Please take note that in the standard form, as “trade date “, the investor must indicate the date of the deposit to the public
register.
23
The publication is made within five days of registration with the public register in the following cases: a) resolution for a share
capital increase on a free basis b) reduction of capital due to losses and c) resolutions passed by the general and special
shareholders' meetings, which order the mandatory conversions of shares of a category of shares to another category. In
addition, in case of increased voting rights or multiple-voting shares the total amount of the voting rights is communicated to the
public by the issuer within the fifth trading day from the end of each calendar month during which an increase of a decrease of
such an amount has occurred. For the relevant rule, please see:
http://www.consob.it/mainen/documenti/english/laws/reg11971e.htm#Article_85-bis
42
Deadline for notifying on-exchange
transactions under TD Art. 12(2) and
L2D Art. 9 / Article 121, paragraphs 1
and 1-ter, of the Issuers’ Regulation no.
11971 of 14 May 1999
The deadline for notifying covers the
maximum permitted time for learning of
the triggering event and for making the
notification.
Five trading days following triggering event
Notifying the National Competent
Authority
- Permitted channel(s)
Certified email
(consob@pec.consob.it)
Email with electronic
signature
(protocollo@consob.it)
Digital portal
24
(https://www.conso
b.it/partril-web/)
Post (Via G. B.
Martini, 3, 00198
Rome, Italy
25
)
- Permitted format(s)
Word
Readable PDF
Notifying the issuer
- Permitted channel(s)
No rule
- Permitted format(s)
No rule
Signature of notification required when
notification is submitted
To the NCA: Yes
To the issuer: No
rule
Intra-day netting
Intra-day netting means that a
shareholder who exceeds a notification
threshold and falls below the same
notification threshold later in the same
trading day nets the voting rights for the
calculation of the notification position.
Permitted
In the event of several transactions carried out
on the same trading day, the holding to be
considered for the purpose of acquitting the
obligations shall be that emerging from the last
transaction carried out (Art. 118, paragraph 6,
of the Issuers’ Regulation no. 11971 of 14 May
1999)
Entity responsible for publishing
notifications under TD Art. 12 / Art. 122,
of the Issuers’ Regulation no. 11971 of
14 May 1999
National Competent Authority
Deadline for publication after the date of
receipt of notification
Three trading days after the day on which the
notification was received
24
The digital portal is used only by issuers for the disclosure of their holdings.
25
The notification may be forwarded in advance by e-mail to vigilanzaopaeassetti@consob.it or by fax to the number +39 06
8477519.
43
Link to standard form (if applicable)
http://www.consob.it/documenti/english/laws/a
nnex4_reg11971e.pdf?lang=en
Link to national central storage
mechanism for regulated information
(OAM)
http://www.1info.it/PORTALEONEINFO/
http://www.emarketstorage.com/home/homepa
ge.htm
Contact details for National Competent
Authority if further information is needed
vigilanzaopaeasse[email protected]
44
Latvia
National Competent Authority
Financial and Capital Market Commission
Applicable national notification
thresholds (percentages)
5, 10, 15, 20, 25, 30, 50, 75, 90
For further information, please refer to
www.fktk.lv
Standard form
Required (for link please see section D below)
Triggering event
The triggering event is the point in time
at which a shareholder reaches, exceeds
or falls below a notification threshold.
- Triggering event for on-exchange
transactions under TD Art. 9(1) /
Law on the Financial Instruments
Market, Article 61, Article 61.
2
,
Article 61.
3
(1)
On-exchange transactions are
transactions which are carried
out on a regulated market.
Settlement date
- Triggering event for passive
crossings, i.e. when there is a
change in the breakdown of
voting rights under TD Art. 9(2) /
Law on the Financial Instruments
Market, Article 61, Article 61.
1
(1)
and (9), Article 61.
3
(1)
Registration of new shares
Deadline for notifying on-exchange
transactions under TD Art. 12(2) and
L2D Art. 9 / Law on the Financial
Instruments Market, Article 61.
3
(1) and
Article 61.
3
(2)
The deadline for notifying covers the
maximum permitted time for learning of
the triggering event and for making the
notification.
Four trading days following triggering event
45
Notifying the National Competent
Authority
- Permitted channel(s)
Email ([email protected])
Post (Kungu iela 1,
Riga, Latvia, LV-
1050)
- Permitted format(s)
No rule
Notifying the issuer
- Permitted channel(s)
Email
Post
- Permitted format(s)
No rule
Signature of notification required when
notification is submitted
To the NCA: Yes
To the issuer: Yes
Intra-day netting
Intra-day netting means that a
shareholder who exceeds a notification
threshold and falls below the same
notification threshold later in the same
trading day nets the voting rights for the
calculation of the notification position.
Not permitted
Entity responsible for publishing
notifications under TD Art. 12 / Law on
the Financial Instruments Market, Article
61.3 (3)
Issuer
Deadline for publication after the date of
receipt of notification
On the trading day after the day on which the
notification was received
Link to standard form (if applicable)
Normatīvie noteikumi par Finanšu instrumentu
tirgus likumā noteiktās paziņojumiem par
nozīmīgas līdzdalības iegūšanu vai zaudēšanu
izmantojamās veidlapas apstiprināšanu
(likumi.lv) (in Latvian)
Link to national central storage
mechanism for regulated information
(OAM)
https://csri.investinfo.lv/
Contact details for National Competent
Authority if further information is needed
Zane.Medne@bank.lv
Gunta.Ilenane@bank.lv
46
Lithuania
National Competent Authority
Bank of Lithuania
Applicable national notification
thresholds (percentages)
5, 10, 15, 20, 25, 30, 50, 75, 95
For further information, please refer to
https://www.lb.lt/en/fs-issuers (information in
Lithuanian)
Standard form
Required (for link please see section D below)
Triggering event
The triggering event is the point in time
at which a shareholder reaches, exceeds
or falls below a notification threshold.
- Triggering event for on-exchange
transactions under TD Art. 9(1) /
Art. 15 (1)(2) and Art. 18 of The
Law on Securities
26
On-exchange transactions are
transactions which are carried
out on a regulated market.
Trade date
- Triggering event for passive
crossings, i.e. when there is a
change in the breakdown of
voting rights under TD Art. 9(2) /
See the reference to the Law
above
27
Registration of new shares
26
https://e-seimas.lrs.lt/portal/legalAct/lt/TAD/TAIS.291834/asr
27
There are no particular provisions in the law on the triggering event for passive crossings. Common market practice and
recommendations of the National Competent Authority are used in this case.
47
Deadline for notifying on-exchange
transactions under TD Art. 12(2) and
L2D Art. 9 / Art. 15 (1) of the Law on
Securities
28
and part 26of the rules on
information disclosure
29
The deadline for notifying covers the
maximum permitted time for learning of
the triggering event and for making the
notification.
Six trading days following triggering event
Notifying the National Competent
Authority
- Permitted channel(s)
Email ([email protected])
or documents by post
Post (Bank of
Lithuania, Zalgirio str.
90, LT-09303)
- Permitted format(s)
Scanned document,
readable PDF
(documents signed
with an electronic
signature)
Scanned document,
readable PDF
(documents signed
with an electronic
signature or originals
with a signature in
Word)
Notifying the issuer
- Permitted channel(s)
Email
Post
- Permitted format(s)
Word
Readable PDF
Signature of notification required when
notification is submitted
To the NCA: Yes
To the issuer: Yes
Intra-day netting
Intra-day netting means that a
shareholder who exceeds a notification
threshold and falls below the same
notification threshold later in the same
trading day nets the voting rights for the
calculation of the notification position.
Permitted
Entity responsible for publishing
notifications under TD Art. 12 / Art. 15(9)
of the Law on Securities
30
Issuer
Deadline for publication after the date of
receipt of notification
Three trading days after the day on which the
notification was received
28
https://e-seimas.lrs.lt/portal/legalAct/lt/TAD/11ef1d803cfb11e68f278e2f1841c088?jfwid=5sjolfxzh
29
https://www.e-tar.lt/portal/lt/legalAct/94a4aec0875511e7a3c4a5eb10f04386/asr
30
https://e-seimas.lrs.lt/portal/legalAct/lt/TAD/11ef1d803cfb11e68f278e2f1841c088?jfwid=5sjolfxzh
48
Link to standard form (if applicable)
https://www.lb.lt/en/reporting-forms-8
Link to national central storage
mechanism for regulated information
(OAM)
http://www.crib.lt/
Contact details for National Competent
Authority if further information is needed
Aurelija Gasiuniene
Email: agasiuniene@lb.lt
49
Luxembourg
National Competent Authority
Commission de Surveillance du Secteur
Financier (CSSF)
Applicable national notification
thresholds (percentages)
5, 10, 15, 20, 25, 1/3, 50, 2/3
For further information, please refer to
https://www.cssf.lu/en/information-
requirements-issuers-of-securities/
Standard form
Required
Triggering event
The triggering event is the point in time
at which a shareholder reaches, exceeds
or falls below a notification threshold.
- Triggering event for on-exchange
transactions under TD Art. 9(1) /
TL
31
Art. 8(1)
On-exchange transactions are
transactions which are carried
out on a regulated market.
Trade date
- Triggering event for passive
crossings, i.e. when there is a
change in the breakdown of
voting rights under TD Art. 9(2) /
TL Art. 8(2)
Publication under TD Art. 15 / TL Art. 14
− Deadline for publication under TD
Art. 15
End of month
Deadline for notifying on-exchange
transactions under TD Art. 12(2) and
L2D Art. 9 / TL Art. 11(2) and TR
32
Art.
10
The deadline for notifying covers the
maximum permitted time for learning of
the triggering event and for making the
notification.
Six trading days following triggering event
31
Law of 11 January 2008 on transparency requirements for issuers (“TL”).
32
Grand-ducal regulation of 11 January 2008 on transparency requirements for issuers of securities (“TR”).
50
Notifying the National Competent
Authority
- Permitted channel(s)
- Permitted format(s)
eRIIS (CSSF online portal)
eRIIS form HOS-1 Major holding notification
Notifying the issuer
- Permitted channel(s)
No rule
- Permitted format(s)
eRIIS form HOS-1 Major holding notification
(PDF format)
Signature of notification required when
notification is submitted
To the NCA: No
To the issuer: No
Intra-day netting
Intra-day netting means that a
shareholder who exceeds a notification
threshold and falls below the same
notification threshold later in the same
trading day nets the voting rights for the
calculation of the notification position.
Permitted, provided that the voting rights are
not exercised
Entity responsible for publishing
notifications under TD Art. 12 / TL Art. 11
Issuer
Deadline for publication after the date of
receipt of notification
Three trading days after the day on which the
notification was received
Link to standard form (if applicable)
The standard form HOS-1 is only accessible
through our online portal eRIIS (further details
may be found at https://www.cssf.lu/en/eriis/
Link to national central storage
mechanism for regulated information
(OAM)
https://bourse.lu/oam
Contact details for National Competent
Authority if further information is needed
transpare[email protected]
51
Malta
National Competent Authority
Malta Financial Services Authority
Applicable national notification
thresholds (percentages)
5, 10, 15, 20, 25, 30, 50, 75, 90
For further information, please refer to
https://www.mfsa.mt/wp-
content/uploads/2021/12/Full-Capital-Markets-
Rules-as-amended-on-6-December-2021.pdf
Standard form
No standard form (Whilst shareholders are not
required to file the notification using a standard
form, they are highly encouraged to use
ESMA's standard notification form for this
purpose. ESMA’s standard form for notification
of major holdings is available on the
Authority's website, as outlined in Section D
below. Regardless of the form used,
notifications shall include all the information as
required in terms of the Capital Markets Rules
transposing the TD provisions.
Triggering event
The triggering event is the point in time
at which a shareholder reaches, exceeds
or falls below a notification threshold.
- Triggering event for on-exchange
transactions under TD Art. 9(1) /
Capital Markets Rule 5.176
On-exchange transactions are
transactions which are carried
out on a regulated market.
Settlement date
- Triggering event for passive
crossings, i.e. when there is a
change in the breakdown of
voting rights under TD Art. 9(2) /
Capital Markets Rule 5.179
Publication of the results of the share capital
increase
52
Deadline for notifying on-exchange
transactions under TD Art. 12(2) and
L2D Art. 9 / Capital Markets Rule 15.193
The deadline for notifying covers the
maximum permitted time for learning of
the triggering event and for making the
notification.
Four trading days following triggering event
Notifying the National Competent
Authority
- Permitted channel(s)
Email
(transparency@mfsa.
mt)
Post (Malta Financial
Services Authority,
Triq l-Imdina, Zone 1,
Central Business
District, Birkirkara,
CBD 1010, Malta)
- Permitted format(s)
No rule
Notifying the issuer
- Permitted channel(s)
No rule
- Permitted format(s)
No rule
Signature of notification required when
notification is submitted
To the NCA: Yes
To the issuer: Yes
Intra-day netting
Intra-day netting means that a
shareholder who exceeds a notification
threshold and falls below the same
notification threshold later in the same
trading day nets the voting rights for the
calculation of the notification position.
Not permitted
Entity responsible for publishing
notifications under TD Art. 12 / Capital
Markets Rule 5.16.8 / 5.193 / 5.197
Issuer
Deadline for publication after the date of
receipt of notification
Three trading days after the day on which the
notification was received
Link to standard form (if applicable)
The recommended ESMA notification can be
found at: https://www.mfsa.mt/our-
work/capital-markets-supervision/ (Listed
Entities > Continuing Obligations > ESMA
Documents)
53
Link to national central storage
mechanism for regulated information
(OAM)
https://www.borzamalta.com.mt/officially-
appointed-mechanism
Contact details for National Competent
Authority if further information is needed
CapitalMarkets@mfsa.mt
54
Netherlands
National Competent Authority
Stichting Autoriteit Financiële Markten (AFM)
Applicable national notification
thresholds (percentages)
3, 5, 10, 15, 20, 25, 30, 40, 50, 60, 75, 95
For further information, please refer to
https://www.afm.nl/en/professionals/doelgroep
en/effectenuitgevende-
ondernemingen/meldingen/substantieel
Standard form
Required (for link please see section D below)
Triggering event
The triggering event is the point in time
at which a shareholder reaches, exceeds
or falls below a notification threshold.
- Triggering event for on-exchange
transactions under TD Art. 9(1) /
5:38 The Financial Supervision
Act (Wft)
On-exchange transactions are
transactions which are carried
out on a regulated market.
Trade date
- Triggering event for passive
crossings, i.e. when there is a
change in the breakdown of
voting rights under TD Art. 9(2) /
5:39 The Financial Supervision
Act (Wft)
Publication under TD Art. 15 / 5:34 The
Financial Supervision Act (Wft)
− Deadline for publication under TD
Art. 15
Increases or decreases larger than 1% must
be notified forthwith while smaller changes
must be notified on a quarterly basis
Deadline for notifying on-exchange
transactions under TD Art. 12(2) and
L2D Art. 9 / 5:38 The Financial
Supervision Act (Wft)
Without delay
33
33
A person is obliged to notify without delay once it has reached, exceeded or fallen below a threshold. “Without delay” means
that the time between the moment a person becomes, or should have become, aware of reaching, exceeding or falling below a
threshold, or aware of the acquisition or loss of the disposal of one or more shares with a special right under the articles of
association regarding control, and the moment the AFM receives the notification, must be as short as possible given the
circumstances. According to Dutch legal provisions, one should have become aware of a triggering event within two working
days.
55
The deadline for notifying covers the
maximum permitted time for learning of
the triggering event and for making the
notification.
Notifying the National Competent
Authority
- Permitted channel(s)
Digital portal
(https://www.loket.afm.nl/loket/en-
GB/default2.aspx)
- Permitted format(s)
HTML
Notifying the issuer
- Permitted channel(s)
No rule
- Permitted format(s)
No rule
Signature of notification required when
notification is submitted
To the NCA: No
To the issuer: No
Intra-day netting
Intra-day netting means that a
shareholder who exceeds a notification
threshold and falls below the same
notification threshold later in the same
trading day nets the voting rights for the
calculation of the notification position.
Permitted
Entity responsible for publishing
notifications under TD Art. 12 / 5:49 The
Financial Supervision Act (Wft)
National Competent Authority
Deadline for publication after the date of
receipt of notification
On the trading day after the day on which the
notification was received by the NCA
Link to standard form (if applicable)
https://www.loket.afm.nl/loket/en-
GB/default2.aspx
Link to national central storage
mechanism for regulated information
(OAM)
https://www.afm.nl/en/professionals/registers/a
lle-huidige-registers.aspx
Contact details for National Competent
Authority if further information is needed
melde[email protected]
56
Norway
National Competent Authority
The Financial Supervisory Authority of Norway
Notifications are received by the Oslo Stock
Exchange Euronext by delegation of this task.
Applicable national notification
thresholds (percentages)
5, 10, 15, 20, 25, 1/3, 50, 2/3, 90
For further information, please refer to
Oslo Stock Exchange Euronext
https://www.euronext.com/en/markets/oslo
Finanstilsynet www.finanstilsynet.no
Standard form
No standard form.
Mandatory requirements regarding the content
of notifications follow from the Securities
Trading Regulation (STR) section 4-1.
Triggering event
The triggering event is the point in time
at which a shareholder reaches, exceeds
or falls below a notification threshold.
- Triggering event for on-exchange
transactions under TD Art. 9(1) /
NSTA, section 4-3 (6)
On-exchange transactions are
transactions which are carried
out on a regulated market.
The entering into of the agreement on
acquisition or disposal, or when the
shareholder learns or should have learned
about this.
- Triggering event for passive
crossings, i.e. when there is a
change in the breakdown of
voting rights under TD Art. 9(2) /
NSTA, section 4-3 (6)
Registration of the new shares, or when the
shareholder learns or should have learned
about this.
Deadline for notifying on-exchange
transactions under TD Art. 12(2) and
L2D Art. 9 / NSTA, section 4-3 (6)
The deadline for notifying covers the
maximum permitted time for learning of
the triggering event and for making the
notification.
Immediately after the transaction which
crosses the threshold is done. In cases where
the crossing is done by a group which holds
shares across different entities and different
time zones, or an asset manager which carry
out asset management for different funds
across different time zones, this may be taken
into consideration when deciding the deadline.
However, such groups or managers must have
routines in place making it possible to notify
the market quickly. In any case the final
deadline is before opening of the market the
57
second day after the trade which leads to the
crossing of the threshold.
Notifying the National Competent
Authority
- Permitted channel(s)
Email
([email protected])
Fax (+4722416590)
- Permitted format(s)
No rule, but mandatory requirements regarding
the content of notifications derive from the
Securities Trading Regulation (STR), section
4-1.
Notifying the issuer
- Permitted channel(s)
No rule, but mandatory requirements regarding
the content of notifications derive from the
Securities Trading Regulation (STR), section
4-1
- Permitted format(s)
No mandatory form, but mandatory
requirements regarding the content of
notifications derive from the Securities Trading
Regulation (STR), section 4-1.
Signature of notification required when
notification is submitted
To the NCA: No
To the issuer: No
Intra-day netting
Intra-day netting means that a
shareholder who exceeds a notification
threshold and falls below the same
notification threshold later in the same
trading day nets the voting rights for the
calculation of the notification position.
Not permitted
Entity responsible for publishing
notifications under TD Art. 12 / NSTA,
section 4-3 subsection (1) and
Regulations on the submission of
disclosure notification etc., of 6
December 2007 no 1359 section 1
The regulated market on which the shares are
admitted to trading - Oslo Stock Exchange
Euronext
Deadline for publication after the date of
receipt of notification
Notification must be published in an effective
and non-discriminating manner; no deadline in
terms of days has been defined
Link to standard form (if applicable)
Not applicable
58
Link to national central storage
mechanism for regulated information
(OAM)
https://newsweb.oslobors.no/
Contact details for National Competent
Authority if further information is needed
Finanstilsynet +4722939800
post@finanstilsynet.no
Erik Landa
erla@finanstilsynet.no
Anne Simonine Egeland
ase@finanstilsynet.no
59
Poland
National Competent Authority
Polish Financial Supervision Authority (KNF)
Applicable national notification
thresholds (percentages)
5, 10
34
, 15, 20, 25, 33
35
, 1/3, 50, 75, 90
For further information, please refer to
http://www.knf.gov.pl
Standard form
No standard form (There is no obligation to
use a standard form for major holdings
notifications. All legal requirements are
contained in the Art. 69. 4. of the Act of 29 July
2005
36
)
Triggering event
The triggering event is the point in time
at which a shareholder reaches, exceeds
or falls below a notification threshold.
- Triggering event for on-exchange
transactions under TD Art. 9(1) /
Art. 69. 1 Act of 29 July 2005
On-exchange transactions are
transactions which are carried
out on a regulated market.
Trade date
- Triggering event for passive
crossings, i.e. when there is a
change in the breakdown of
voting rights under TD Art. 9(2) /
Art. 69. 1 Act of 29 July 2005
Registration of new shares
Deadline for notifying on-exchange
transactions under TD Art. 12(2) and
L2D Art. 9 / Art. 69. 1 Act of 29 July 2005
The deadline for notifying covers the
maximum permitted time for learning of
the triggering event and for making the
notification.
Six trading days following triggering event for
on-exchange transactions and four working
days for off-exchange transactions
34
Shareholders who have crossed the 10% threshold are required to notify any increase or decrease in their holdings which is
equal to or greater than a) 2% in case of companies admitted to trading on the official listing of the regulated markets; and b)
5% in case of companies admitted to trading other market segments of the regulated market or admitted to trading on an MTF.
35
Shareholders who have crossed the 33% threshold are required to notify any increase or decrease in their holdings which is
equal to or greater than 1%.
36
Act of 29 July 2005 on Public Offering, Conditions Governing the Introduction of Financial Instruments to Organised Trading,
and Public Companies
60
Notifying the National Competent
Authority
- Permitted channel(s)
Electronic portal:
www.epuap.gov.pl
37
Email
38
(znaczne.pakiety@knf
.gov.pl)
Fax (0048222625532)
Post (Komisja
Nadzoru
Finansowego, ul.
Piękna 20, 00-549
Warszawa)
- Permitted format(s)
No rule
Notifying the issuer
- Permitted channel(s)
No rule
- Permitted format(s)
No rule
Signature of notification required when
notification is submitted
To the NCA: Yes
To the issuer: Yes
Intra-day netting
Intra-day netting means that a
shareholder who exceeds a notification
threshold and falls below the same
notification threshold later in the same
trading day nets the voting rights for the
calculation of the notification position.
Permitted
Entity responsible for publishing
notifications under TD Art. 12 / Art. 70 p.
1 Act of 29 July 2005
Issuer
Deadline for publication after the date of
receipt of notification
On the day on which the notification was
received
Link to standard form (if applicable)
Not applicable
Link to national central storage
mechanism for regulated information
(OAM)
https://moam.knf.gov.pl/moam.nsf
Contact details for National Competent
Authority if further information is needed
[email protected]
37
KNF Electronic inbox: /2447pvjake/SkrytkaESP.
38
Additional channel to be used only in case of emergency or risk of postal delay.
61
Portugal
National Competent Authority
Comissão do Mercado de Valores Mobiliários
Applicable national notification
thresholds
39
(percentages)
5, 10, 15, 20, 25, 1/3, 50, 2/3, 90
For further information, please refer to
https://www.cmvm.pt/en/Legislacao/National_l
egislation/Securities%20Code/Documents/EN
%20CdVM_20220228.clean.pdf
Standard form
Optional (The use of the ESMA Standard Form
is recommended, for link please see section D
below)
Triggering event
The triggering event is the point in time
at which a shareholder reaches, exceeds
or falls below a notification threshold.
- Triggering event for on-exchange
transactions under TD Art. 9(1) /
Art 16/1 Portuguese Securities
Code
On-exchange transactions are
transactions which are carried
out on a regulated market.
Trade date
- Triggering event for passive
crossings, i.e. when there is a
change in the breakdown of
voting rights under TD Art. 9(2) /
Art 16/1 Portuguese Securities
Code
Registration of new shares
Deadline for notifying on-exchange
transactions under TD Art. 12(2) and
L2D Art. 9 / Art. 16/1 and 16/3
Portuguese Securities Code
The deadline for notifying covers the
maximum permitted time for learning of
the triggering event and for making the
notification.
Six trading days following triggering event
39
Some of these thresholds are also applicable to “sociedades abertas” which are issuers considered public companies in
Portugal but whose shares are not admitted to trading on a regulated market. The obligation to notify major holdings in
“sociedades abertas” only applies until 31/12/2022 (as from that date the concept “sociedades abertas” will be supressed from
Portuguese law).
62
Notifying the National Competent
Authority
- Permitted channel(s)
Email
(cmvm@cmvm.pt)
Fax
(+35121353077/8)
Post (r. Laura Alves,
nº 4 - Apartado 14258
1064-003 Lisboa)
- Permitted format(s)
Word
Excel
Readable PDF
Notifying the issuer
- Permitted channel(s)
Email
Fax
Post
- Permitted format(s)
Word
Excel
Readable PDF
Signature of notification required when
notification is submitted
To the NCA: No
To the issuer: No
Intra-day netting
Intra-day netting means that a
shareholder who exceeds a notification
threshold and falls below the same
notification threshold later in the same
trading day nets the voting rights for the
calculation of the notification position.
Permitted
Entity responsible for publishing
notifications under TD Art. 12 / Art 17
Portuguese Securities Code
Issuer
Deadline for publication after the date of
receipt of notification
Three trading days after the day on which the
notification was received
Link to standard form (if applicable)
http://web3.cmvm.pt/SDI/emitentes/FORM_PQ
_esma-2015-1597.pdf
Link to national central storage
mechanism for regulated information
(OAM)
http://web3.cmvm.pt/english/sdi/emitentes/info
_priv.cfm
Contact details for National Competent
Authority if further information is needed
transparency@cmvm.pt
63
Romania
National Competent Authority
Financial Supervisory Authority (ASF - former
CNVM)
Applicable national notification
thresholds (percentages)
5, 10, 15, 20, 25, 33, 50, 75
For further information, please refer to
https://www.asfromania.ro/ro/a/944/emiten%C8
%9Bi
Standard form
Required (for link please see section D below)
Triggering event
The triggering event is the point in time
at which a shareholder reaches, exceeds
or falls below a notification threshold.
- Triggering event for on-exchange
transactions under TD Art. 9(1) /
Art. 71 paragraph (1) and Art. 74
paragraph (2) of Law no. 24/2017
on issuers of financial
instruments and market
operations as amended, , Art.
137 of ASF Regulation no.
5/2018 on issuers of financial
instruments and market
operations as amended , and Art.
5 of ASF Regulation no. 4/2013
regarding the underlying shares
for the certificates of deposit, with
subsequent modifications
On-exchange transactions are
transactions which are carried
out on a regulated market.
Settlement date
- Triggering event for passive
crossings, i.e. when there is a
change in the breakdown of
voting rights under TD Art. 9(2) /
Art. 71 paragraph (2) of Law no.
24/2017 on issuers of financial
Publication under TD Art. 15 / Art. 71
paragraph (4) of Law no. 24/2017 on issuers of
financial instruments and market operations
40
40
While Art. 71 paragraph (4) of Law 24/2017 on issuers of financial instruments and market operations as amended, obliges
the issuer to disclose the total number of shares and accompanying voting rights at the end of each calendar month in which an
increase or a decrease in the share capital or voting rights occurred, in practice this information is published immediately by the
central depository on the website of the market operator.
64
instruments and market
operations as amended,
Deadline for notifying on-exchange
transactions under TD Art. 12(2) and
L2D Art. 9 / Art. 74 paragraph (2) of Law
no. 24/2017 on issuers of financial
instruments and market operations as
amended, Art. 137 of ASF Regulation
no. 5/2018 on issuers of financial
instruments and market operations, with
subsequent modifications and Art. 5 of
ASF Regulation no. 4/2013 regarding the
underlying shares for the certificates of
deposit, with subsequent modifications
The deadline for notifying covers the
maximum permitted time for learning of
the triggering event and for making the
notification.
Four trading days following triggering event
Notifying the National Competent
Authority
- Permitted channel(s)
No rule
- Permitted format(s)
No rule
Notifying the issuer
- Permitted channel(s)
Email (with
incorporated
extended electronic
signature)
Fax
Post
- Permitted format(s)
No rule
Signature of notification required when
notification is submitted
To the NCA: Yes
To the issuer: Yes
Intra-day netting
Intra-day netting means that a
shareholder who exceeds a notification
threshold and falls below the same
notification threshold later in the same
trading day nets the voting rights for the
calculation of the notification position.
Permitted
Entity responsible for publishing
notifications under TD Art. 12 / Art. 74
paragraph (6) of Law no. 24/2017 on
Issuer
41
41
The notification is also published by the regulated market as the issuer is required to file it with the regulated market as well.
65
issuers of financial instruments as
amended, and market operations and
Art. 5 of the ASF Regulation no. 4/2013
regarding the underlying shares for the
certificates of deposit, with subsequent
modifications
Deadline for publication after the date of
receipt of notification
Three trading days after the day on which the
notification was received
Link to standard form (if applicable)
https://www.asfromania.ro/uploads/articole/attac
hments/628b7a455c0ae835801983.pdf
Link to national central storage
mechanism for regulated information
(OAM)
https://oam.asfromania.ro/oam/loadedPDFRep
ortsForPublic.jsp
Contact details for National Competent
Authority if further information is needed
reglementari.siif@asfromania.ro
66
Slovakia
National Competent Authority
National Bank of Slovakia
Applicable national notification
thresholds (percentages)
5, 10, 15, 20, 25, 30, 50, 75
For further information, please refer to
http://www.nbs.sk/en/financial-market-
supervision1/supervision/securities-market
Standard form
Recommended (applicable from 1 January
2017)
Triggering event
The triggering event is the point in time
at which a shareholder reaches, exceeds
or falls below a notification threshold.
- Triggering event for on-exchange
transactions under TD Art. 9(1) /
Art. 7(8,9), Art. 13 of the
Securities and Investment
Services Act No. 566/2001 Coll.
On-exchange transactions are
transactions which are carried
out on a regulated market.
Settlement date
- Triggering event for passive
crossings, i.e. when there is a
change in the breakdown of
voting rights under TD Art. 9(2) /
Art. 202 (4), Art. 213 (7), Art. 216
(1) of the Commercial Code
Registration of new shares
Deadline for notifying on-exchange
transactions under TD Art. 12(2) and
L2D Art. 9 / Art. 41 (11) and Art. 41 (12)
of the Act No. 429/2002 Coll. on Stock
Exchange
The deadline for notifying covers the
maximum permitted time for learning of
the triggering event and for making the
notification.
Six trading days following triggering event
67
Notifying the National Competent
Authority
- Permitted channel(s)
Fax
(+421257871116)
Email
(oznamovanie.podielo
v@nbs.sk)
Post (Národná banka
Slovenska, Imricha
Karvaša 1813 25
Bratislava, Slovak
Republic)
- Permitted format(s)
No rule
Notifying the issuer
- Permitted channel(s)
No rule
- Permitted format(s)
No rule
Signature of notification required when
notification is submitted
To the NCA: Yes
To the issuer: Yes
Intra-day netting
Intra-day netting means that a
shareholder who exceeds a notification
threshold and falls below the same
notification threshold later in the same
trading day nets the voting rights for the
calculation of the notification position.
Not permitted
Entity responsible for publishing
notifications under TD Art. 12 / Art. 42
(11) of the Act. No. 429/2002 Coll. on
Stock Exchange
Issuer
42
Deadline for publication after the date of
receipt of notification
Three trading days after the day on which the
notification was received
Link to standard form (if applicable)
http://www.nbs.sk/en/financial-market-
supervision1/supervision/securities-
market/issuers-of-securities-basic-information
Link to national central storage
mechanism for regulated information
(OAM)
https://ceri.nbs.sk/
42
According to the Art. 42 (12) of the Act. No. 429/2002 Coll. on Stock Exchange where the National Bank of Slovakia
discloses the information referred to in Article 41(13) no later than three trading days after receiving the notification, and
provided that conditions set out in Article 47 are met, the issuer shall be exempted from the obligation under Article 41(11) to
disclose the information.
68
Contact details for National Competent
Authority if further information is needed
Národná banka Slovenska, Imricha Karvaša 1,
813 25 Bratislava, Slovak Republic,
[email protected]
69
Slovenia
National Competent Authority
Securities Market Agency (SMA)
Applicable national notification
thresholds (percentages)
5, 10, 15, 20, 25, 1/3, 50, 75
For further information, please refer to
ZTFI-1-npb1_ANG 2020_web.pdf (a-tvp.si)
Financial Instruments Market Act (ZTFI-1)
Standard form
Required (for link please see section D below)
Triggering event
The triggering event is the point in time
at which a shareholder reaches, exceeds
or falls below a notification threshold.
- Triggering event for on-exchange
transactions under TD Art. 9(1) /
ZTFI Art. 118/1/1
43
On-exchange transactions are
transactions which are carried
out on a regulated market.
Trade date
- Triggering event for passive
crossings, i.e. when there is a
change in the breakdown of
voting rights under TD Art. 9(2) /
ZTFI Art. 118/1/2
44
Registration of new shares
Deadline for notifying on-exchange
transactions under TD Art. 12(2) and
L2D Art. 9 / ZTFI Art. 123/2
The deadline for notifying covers the
maximum permitted time for learning of
the triggering event and for making the
notification.
Four trading days following triggering event
Notifying the National Competent
Authority
- Permitted channel(s)
Email
[email protected]
Fax
Post
Securities Market
Agency,
43
More specific rules are set out in by-laws which are not translated to English.
44
More specific rules are set out in by-laws which are not translated to English.
70
+386 (0)1 280 04 30
Poljanski nasip 6,
1000 Ljubljana,
Slovenia
- Permitted format(s)
No rule
Notifying the issuer
- Permitted channel(s)
No rule
- Permitted format(s)
No rule
Signature of notification required when
notification is submitted
To the NCA: Yes
To the issuer: Yes
Intra-day netting
Intra-day netting means that a
shareholder who exceeds a notification
threshold and falls below the same
notification threshold later in the same
trading day nets the voting rights for the
calculation of the notification position.
Permitted
Entity responsible for publishing
notifications under TD Art. 12 / ZTFI Art.
124/1
Issuer
Deadline for publication after the date of
receipt of notification
Three trading days after the day on which the
notification was received
Link to standard form (if applicable)
https://www.a-
tvp.si/storage/app/media/Documents/obrazci/Z
TFI-1/Obrazec_P_DEL.pdf (in Slovenian)
Link to national central storage
mechanism for regulated information
(OAM)
INFO STORAGE - Officially appointed
mechanism for the central storage of regulated
information (oam.si)
Contact details for National Competent
Authority if further information is needed
tanja.gorse@atvp.si
tanja.lov[email protected]
71
Spain
National Competent Authority
Comisión Nacional del Mercado de Valores
(CNMV)
Applicable national notification
thresholds
45
(percentages)
3, 5, 10, 15, 20, 25, 30, 35, 40, 45, 50, 60, 70,
75, 80, 90
For further information, please refer to
https://www.cnmv.es/docPortal/legislacion/real
decre/RD1362_2007_ingles.pdf
46
http://www.cnmv.es/DocPortal/Legislacion/Circ
ulares/Circular_2_2022_EN.pdf
47
Standard form
Required (for link please see section D below)
Triggering event
The triggering event is the point in time
at which a shareholder reaches, exceeds
or falls below a notification threshold.
- Triggering event for on-exchange
transactions under TD Art. 9(1) /
Royal Decree 1362/2007 of 19
October 2007 Art.23.1
On-exchange transactions are
transactions which are carried
out on a regulated market.
Trade date
- Triggering event for passive
crossings, i.e. when there is a
change in the breakdown of
voting rights under TD Art. 9(2) /
Publication under TD Art. 15 / Royal Decree
1362/2007 of 19 October 2007 Art. 38.2
45
Further to these thresholds and as part of its transposition of the Transparency Directive, Spain has laid down thresholds in
relation to shares in companies under a takeover bid. For such companies, shareholders have to notify each time they reach or
cross a 1% threshold. If the shareholder holds more than 3% of voting rights in the company, (s)he has to notify every transaction.
Other countries may have similar requirements, however these will more often be laid down in the legislation transposing the
Takeover Bids Directive and are therefore not mentioned in this document. Additionally, in its transposition of the Transparency
Directive, Spain has put in place specific notification thresholds for shareholders which are residents in tax havens, nil tax
countries or countries with which no effective exchange of tax information is in place; such shareholders have to notify each time
they reach/cross a 1% threshold.
46
Royal Decree 1362/2007 of 19 October 2007 implementing Law 24/1988, of 28 July on transparency requirements in relation
to information about issuers whose securities are admitted to trading on an organized exchange or other regulated market in the
European Union.
47
Circular 2/2022, of 26 May, of the Spanish National Securities Market Commission, approving the templates for notification of
significant shareholdings, issuer transactions in treasury stock and market makers. To incentivize long-term investments Spanish
Company Law introduced loyalty shares. Under these provisions, Spanish companies with shares admitted to trading on a
regulated market are allowed to include in their by-laws the possibility of granting additional voting rights to shareholders for each
share held continuously for at least two years. The Spanish notification form for major holdings has been modified to allow
inclusion of information related to loyalty shares. A new section 11 has been added to facilitate the disclosure of more detailed
information on loyalty shares.
72
Royal Decree 1362/2007 of 19
October 2007 Art. 23.3
− Deadline for publication under TD
Art. 15
End of month
Deadline for notifying on-exchange
transactions under TD Art. 12(2) and
L2D Art. 9 / Royal Decree 1362/2007 of
19 October 2007 Art. 35.1
The deadline for notifying covers the
maximum permitted time for learning of
the triggering event and for making the
notification.
Six trading days following triggering event
Notifying the National Competent
Authority
- Permitted channel(s)
Digital portal
(https://www.cnmv.es/
Portal/Legislacion/Mo
delosN/ModelosN.asp
x?id=COM&lang=en )
Post (Edison, 4,
28006 Madrid, Spain)
- Permitted format(s)
XML
Notifying the issuer
- Permitted channel(s)
No rule
- Permitted format(s)
No rule
Signature of notification required when
notification is submitted
To the NCA: Yes
To the issuer: No rule
Intra-day netting
Intra-day netting means that a
shareholder who exceeds a notification
threshold and falls below the same
notification threshold later in the same
trading day nets the voting rights for the
calculation of the notification position.
Permitted
48
48
Royal Decree 1362/2007 of 19 October 2007 Art. 36.1.
73
Entity responsible for publishing
notifications under TD Art. 12 / Royal
Decree 1362/2007 of 19 October 2007
Art. 38.1
National Competent Authority
Deadline for publication after the date of
receipt of notification
Three trading days after the day on which the
notification was received
Link to standard form (if applicable)
https://www.cnmv.es/Portal/Legislacion/Model
osN/ModelosN.aspx?id=COM&lang=en
Link to national central storage
mechanism for regulated information
(OAM)
http://www.cnmv.es/Portal/Consultas/IndiceEI
R.aspx?lang=en
Contact details for National Competent
Authority if further information is needed
DIFC-informacion@cnmv.es
74
Sweden
National Competent Authority
Finansinspektionen (Swedish Financial
Supervisory Authority)
Applicable national notification
thresholds
49
(percentages)
5, 10, 15, 20, 25, 30, 50, 2/3, 90
For further information, please refer to
http://www.fi.se/en/markets/reporting/changes-
in-shareholdings
Standard form
Optional (Finansinspektionen has drawn up an
own notification form, but does not strictly
require this to be used, as the legal
requirement is simply to submit the notification
“in writing”.)
Triggering event
The triggering event is the point in time
at which a shareholder reaches, exceeds
or falls below a notification threshold.
- Triggering event for on-exchange
transactions under TD Art. 9(1) /
Chapter 4, paragraph 3 and 5 of
the Financial Instruments Trading
Act (SFS 1991:980)
On-exchange transactions are
transactions which are carried
out on a regulated market.
Trade date
- Triggering event for passive
crossings, i.e. when there is a
change in the breakdown of
voting rights under TD Art. 9(2) /
Chapter 4, paragraph 9 section 2
of the Financial Instruments
Trading Act (SFS 1991:980)
Publication under TD Art. 15 / Chapter 4,
paragraph 9 section 1 of the Financial
Instruments Trading Act (SFS 1991:980)
− Deadline for publication under TD
Art. 15
End of month (last trading day
50
)
49
The notification thresholds apply to both holdings of shares and of voting rights in Sweden.
50
In Sweden the requirement is that publication takes place on the last trading day of the month, regardless of whether there
has been a prior publication or not.
75
Deadline for notifying on-exchange
transactions under TD Art. 12(2) and
L2D Art. 9 / Chapter 4, paragraph 10 of
the Financial Instruments Trading Act
(SFS 1991:980)
The deadline for notifying covers the
maximum permitted time for learning of
the triggering event and for making the
notification.
Three trading days following triggering event
Notifying the National Competent
Authority
- Permitted channel(s)
Email
(rapportering@fi.se
and r[email protected])
Digital portal
(https://finanscentrale
n.fi.se/flag.aspx)
Fax (+468241335)
Post
(Finansinspektionen
(Att: Market
Monitoring), Box
7821, 103 97
Stockholm)
- Permitted format(s)
No rule
Notifying the issuer
- Permitted channel(s)
No rule
- Permitted format(s)
No rule
Signature of notification required when
notification is submitted
To the NCA: Yes
To the issuer: No
Intra-day netting
Intra-day netting means that a
shareholder who exceeds a notification
threshold and falls below the same
notification threshold later in the same
trading day nets the voting rights for the
calculation of the notification position.
Permitted
Entity responsible for publishing
notifications under TD Art. 12 / Chapter
4, paragraph 11 of the Financial
Instruments Trading Act (SFS 1991:980)
National Competent Authority
Deadline for publication after the date of
receipt of notification
At 12:00 (mid-day) on the trading day after the
day on which the notification was received
76
Link to standard form (if applicable)
http://www.fi.se/contentassets/15eabba2304c4
27fb44e8c4e5d185ede/flaggning/notificaton-
changes-major-shareholdings-ny.pdf
Link to national central storage
mechanism for regulated information
(OAM)
https://finanscentralen.fi.se/search/Search.asp
x
Contact details for National Competent
Authority if further information is needed
Tel.: +46840898144
Email: listedcompanies@fi.se
77
PART II:
TRANSVERSAL TABLES
Part II of the Practical Guide presents information in relation to the rules and practices for the
filing and publication of notifications of major holdings in EEA countries. The information in
Part II is set out in ten transversal tables, making it possible to compare rules across different
jurisdictions.
• Table 1 presents the notification thresholds applied under TD Art. 9.
• The following tables set out information about the triggering event under TD Art. 9(1)
(Table 2), in cases where the exercise of a physically settled financial instrument leads
to an acquisition of shares with voting rights (Table 3) and under TD Art. 9(2) (Table
4).
• Tables 5 and 6 contain the rules regarding the deadline for learning of the triggering
event under TD Art. 9(1) and 9(2), while Table 7 provides information on the deadline
for making notifications to the issuer.
• Tables 8 and 9 set out the permitted channels and formats for submitting notifications
to National Competent Authorities and issuers.
• Finally, Table 10 presents the deadline for publishing a notification of major holdings.
78
Table 1: Applicable notification thresholds under TD Article 9
Country
Percentage of shareholding
AT
3
1
4
5
10
15
20
25
30
35
40
45
50
75
90
BE
5
10
15
20
25
30
35
40
45
50
55
60
65
70
75
80
85
90
95
BG
5
10
15
20
25
30
35
40
45
50
55
60
65
70
75
80
85
90
95
CY
5
10
15
20
25
30
50
75
CZ
1
2
3
2
5
10
15
20
25
30
40
50
75
DE
3
3
5
10
15
20
25
30
50
75
DK
5
10
15
20
25
1/3
50
2/3
90
EE
5
10
15
20
25
1/3
50
2/3
EL
5
10
4
15
20
25
1/3
50
2/3
ES
5
3
5
10
15
20
25
30
35
40
45
50
60
70
75
80
90
FI
6
5
10
15
20
25
30
50
2/3
90
FR
5
10
15
20
25
30
+
1/3
50
2/3
90
95
HR
5
10
15
20
25
30
50
75
HU
5
10
15
20
25
30
35
40
45
50
75
80
85
90
91
92
93
94
95
96
97
98
99
IE
(IE issuers
except
CEIFs)
3% and each 1% thereafter up to 100%
(non-IE
issuers
and
CEIFs)
5
10
15
20
25
30
50
75
IS
5
10
15
20
25
30
35
40
50
2/3
90
IT
3
7
5
10
8
15
20
8
25
8
30
50
2/3
90
LT
5
10
15
20
25
30
50
75
95
LU
5
10
15
20
25
1/3
50
2/3
LV
5
10
15
20
25
30
50
75
90
MT
5
10
15
20
25
30
50
75
90
NL
3
5
10
15
20
25
30
40
50
60
75
95
NO
5
10
15
20
25
1/3
50
2/3
90
PL9
5
10
15
20
25
33
+
1/3
50
75
90
PT
10
5
10
15
20
25
1/3
50
2/3
90
RO
5
10
15
20
25
33
50
75
SE
11
5
10
15
20
25
30
50
2/3
90
SI
5
10
15
20
25
1/3
50
75
SK
5
10
15
20
25
30
50
75
79
Comments:
While, for the purpose of clarity, the styles “1/3” and “2/3” are used for all countries who have adopted thresholds of one and two
thirds, some countries use a different style in their national legislation, such as “33 1/3” and “66 2/3”.
Mandatory thresholds under TD Article 9 are marked in light blue.
Notes:
1: The threshold of 3% applies only to issuers which have stipulated this threshold value in their articles of association. A special
condition for this to become effective is the publication of the relevant clause of the articles of association on the issuer’s website
and a notification to the FMA.
2: The thresholds of 1% and 3% are "size adjusted" whereby the 3% threshold only applies to holdings in companies with share
capital > 100m CZK and the 1% threshold only applies to holdings in companies with share capital > 500m CZK.
3: The 3% threshold applies only for notifying voting rights (TD Art. 9/10), but not for positions arising out of financial instruments
(TD Art. 13) or aggregated positions (TD Art. 13a).
4: Shareholders who have crossed the 10% threshold are required to notify any increase or decrease in their holdings which is equal
to or greater than 3%.
5: Further to the thresholds in the table, as part of its transposition of the TD Spain has laid down thresholds in relation to shares in
companies under a takeover bid. For such companies, shareholders have to notify each time they reach or cross a 1% threshold. If
the shareholder holds more than 3% of voting rights in the company, (s)he has to notify every transaction. Other countries may have
similar requirements, however these will more often be laid down in the legislation transposing the Takeover Bids Directive and are
therefore not mentioned here. Additionally, in its transposition of the TD Spain has put in place specific notification thresholds for
shareholders which are residents in tax havens, nil tax countries or countries with which no effective exchange of tax information is
in place; such shareholders have to notify each time they reach/cross a 1% threshold.
6: In Finland shareholders are required to notify both voting rights and shares.
7: The 3% threshold is applicable only to holdings in non-SME companies.
8: A declaration of intent, i.e. a statement of investment objectives, will be required when the 10%, 20%, and 25% threshold is
exceeded.
9: Shareholders who have crossed the 10% threshold are required to notify any increase or decrease in their holdings which is equal
to or greater than a) 2% in case of companies admitted to trading on the official listing of the regulated markets; and b) 5% in case
of companies admitted to trading other market segments of the regulated market or admitted to trading on an MTF. Additionally,
shareholders who have crossed the 33% threshold are required to notify any increase or decrease in their holdings which is equal
to or greater than 1%.
10: Some of these thresholds are also applicable to “sociedades abertas”, that is issuers within the Portuguese scope of public
company but whose shares are not admitted to trading on a regulated market. The obligation to notify major holdings in “sociedades
abertas” only applies until 31/12/2022 (as from that date the concept “sociedades abertas” will be supressed from Portuguese law).
11: In Sweden shareholders are required to notify both voting rights and shares.
80
Table 2: Triggering event under TD Art. 9(1)
On-exchange
transactions
Off-exchange
transactions
Exercise of
subscription rights in
share capital increase
Trade date
BE, CY, DE, DK, EE, EL,
ES, FI, FR, HR, HU, IE,
IS, IT, LT, LU, NL, NO,
PL, PT, SE, SI
DE, DK, EE, ES, IS, LT,
LU
Settlement date
AT, BG, CZ, LV, MT, RO,
SK
AT, BG, CZ, HU, LV, MT,
RO, SK
AT, FR, LV
Trade/agreement date
BE, CY, EL, FI, FR, HR,
IE, IT, NL, NO, PT, SE,
SI
Registration date of
share capital increase
BE, BG, CY, DE, ES, FI,
HR, HU, LT, LU, PL, PT,
SE, SK
Publication of total
number of voting rights
under TD Art. 15
DK, EE, IE, IS, IT, RO
1
Start of trading of
shares
EL, MT
Publication of the
share capital increase
results
NO
Exercise of
subscription rights /
Conclusion of
subscription contract
CZ, NL, SI
Miscellaneous
PL
2
Notes:
1: While Art. 71 paragraph (4) of Law 24/2017 on issuers of financial instruments and market operations as
amended obliges the issuer to disclose the total number of shares and accompanying voting rights at the end of
each calendar month in which an increase or a decrease in the share capital or voting rights occurred, in practice
this information is published immediately by the central depository on the website of the market operator.
2: The triggering event takes place on the date on which the shareholder becomes or could become aware of the
change in his/her share in the total number of voting rights.
81
Table 3: Triggering event in cases where the exercise of a physically settled financial instrument leads
to an acquisition of shares with voting rights
Options
Futures
Swaps
Warrants
Date of exercise
BE, BG, CY, DE,
DK, EE, EL, ES,
FR, IE, IS, IT, LT,
LU, NL, PT, SE
NL
BE, BG, CY, DE,
DK, EE, EL, ES,
FR, IE, IS, IT, LU,
NL, PT, SE
Settlement date
AT, CZ, FI, MT,
RO, SK
AT, CZ, FI, MT, PT,
RO, SK
AT, CZ, FI, MT, PT,
RO, SK
AT, CZ, FI, MT,
RO, SK
Date of maturity
BE, BG, CY, DE,
DK, EE, EL, ES,
FR, IE, IS, IT, LU,
NL and SE
Date of
expiration/maturity
BE, BG, CY, DE,
DK, EE, EL, ES,
FR, IE, IS, IT, LU,
SE
Trade/agreement
date
HR, HU, NO, SI
HR, HU, NO, SI
HR, HU, NO, SI
HR, HU, NO, SI
Miscellaneous
LV
1
, PL
1
LT
1
, LV
1
, PL
1
LT
1
, LV
1
, PL
1
LT
1
, LV
1
, PL
1
Notes:
1: Lithuania, Latvia and Poland have no specific rule in relation to this topic.
Table 4: Triggering event under TD Art. 9(2)
Publication of total number of voting rights under
TD Art. 15
CY, DK, EE, ES, FI, HR, IE, IT, LU, NL, RO
1
, SE
Registration date of share capital increase
AT, BE, BG, DE, HU, LT, LV, NO, PL, PT, SI, SK
Publication of the share capital increase results
IS, MT,
Settlement Date
FR
Start of trading of shares
EL
Miscellaneous
CZ
2
Note:
1: While Art. 71 paragraph (4) of Law 24/2017 on issuers of financial instruments and market operations as
amended obliges the issuer to disclose the total number of shares and accompanying voting rights at the end of
each calendar month in which an increase or a decrease in the share capital or voting rights occurred, in practice
this information is published immediately by the central depository on the website of the market operator.
2: A distinction is made between capital decreases for which the triggering event is the registration date in the
company register and capital increases for which the triggering event is the date determined by the issuer at the
shareholders’ meeting which will be not prior to the exercise of subscription rights and not later than on the
registration date in the company register.
82
Table 5: Deadline for learning of triggering event under TD Art. 9(1)
On-exchange transactions
Off-exchange transactions
Two trading days after
triggering event
AT
1
, BE, BG, CY, CZ, DE
2
, EE,
ES, FI, HR, IE, LT, LU, LV, NL,
PT, SK
AT
1
, BE, BG, CY, CZ, DE, EE, FI,
IE, LT, LU, NL, PT, SK
Trading day following the
triggering event
IT
IT
On the same day as the
triggering event
DK, EL, FR, IS, MT, PL, RO, SE,
SI
DK, EL, ES, FR, HR, IS LV, MT,
PL, RO
3
, SE, SI
Miscellaneous
HU
4
, NO
5
HU
4
, NO
5
Notes:
1: Although the notifiable person shall be deemed to have knowledge of the triggering event no later than two
trading days following the transaction and the deadline for making the notification shall be no later than two further
trading days, in general, the notification shall be submitted promptly but not later than two trading days after the
threshold was crossed.
2: The total deadline for disclosing a notification, i.e. learning of the triggering event plus deadline for making the
notification (see table 7), is in in practice generally four trading days. Only in very extraordinary cases may the
deadline of six trading days apply.
3: In case of certain off-exchange transactions, the settlement date is three trading days after the transaction rather
than the generally applicable settlement date of two trading days after the transaction. However, for those off-
exchange transactions, the deadline for learning of the triggering event is still two trading days after the transaction.
4: Hungary does not apply a specific deadline for learning of the triggering event which is considered to take place
immediately after the triggering event.
5: Norway considers the person to have learned when the person becomes aware of or should have been aware
of the transaction after the triggering event.
Table 6: Deadline for learning of triggering event under TD Art. 9(2)
Publication of total number of
voting rights under TD Art. 15
AT, BE, CY, DE, DK, EE, ES, FI, FR, HR, IE, IT, LT, LU, NL, RO
1
, SE
Registration of share capital
increase in company register
BG, CZ, HU, LV, PL, PT, SI
Publication of results of share
capital increase by issuer
IS, MT, SK
Miscellaneous
EL
2
, NO
3
Notes:
1: While Art. 71 paragraph (4) of Law 24/2017 on issuers of financial instruments and market operations as
amended obliges the issuer to disclose the total number of shares and accompanying voting rights at the end of
each calendar month in which an increase or a decrease in the share capital or voting rights occurred, in practice
this information is published immediately by the central depository on the website of the market operator.
2: While the person subject to the notification obligation is assumed to be informed when the publication of the total
number of voting rights under TD Article 15 takes place, this most often takes place before the start of trading of
shares.
3: The matter is assessed on a case-by-case basis.
83
Table 7: Deadline for making notification to the issuer
Same day as learning
DK
1
One trading day after learning
FI
Two trading days after learning
AT, IE
2
Three trading days after
learning
CY, EL, SE
Four trading days after learning
BE, BG, CZ, DE
3
, EE, ES, FR, HR, IE
4
, IS, IT, LT, LU, LV, MT, NL
5
, PT,
RO, SI, SK
Miscellaneous
HU
6
, NO
7,
PL
8
Notes:
1: From 1 January 2018, the deadline for notifying on-exchange transactions under TD Art. 12(2) and L2D Art.
9 will be four trading days after learning (section 41 of the Capital Market act).
2: Applicable to shareholders in all issuers except non-Irish issuers and CEIFs.
3: The total deadline for disclosing a notification, i.e. learning of the triggering event (see table 5) plus deadline
for making the notification, is in in practice generally four trading days. Only in very extraordinary cases may the
deadline of six trading days apply.
4: Applicable to shareholders in non-Irish issuers and CEIFs.
5: As the National Competent Authority informs the issuer of the filing of the notification, shareholders do not
have to submit their notification to the issuer.
6: Hungary applies a deadline of two calendar days after learning.
7: The notification has to be made immediately. In cases where the crossing is done by a group which holds
shares across different entities and different time zones, or an asset manager which carry out asset management
for different funds across different time zones, this may be taken into consideration when deciding the deadline.
However, such groups or managers must have routines in place making it possible to notify the market quickly.
In any case the final deadline is before opening of the market the second day after the trade which leads to the
crossing of the threshold and in any case before opening of the market the second day after the transaction
which leads to the crossing of the threshold.
8: Six trading days following the triggering event for on exchange transactions and four working days for off-
exchange transactions.
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Table 8: Channels for submitting notifications to NCAs and issuers
Email
Digital portal
Fax
Post
NCA
Issuers
NCA
Issuers
NCA
Issuers
NCA
Issuers
AT
x
1
x
x
1
x
1
BE
X
x
BG
X
x
x
x
x
x
CY
X
x
x
CZ
x
x
DE
x
x
x
x
DK
x
EE
X
x
x
EL
X
x
x
ES
x
x
FI
X
FR
X
x
x
HR
x
HU
x
IE
X
IS
X
x
1
IT
x
2
x
x
LT
X
x
x
x
LU
X
x
LV
X
x
x
x
MT
X
x
NL
x
3
x
NO
X
x
PL
X
x
x
PT
4
X
x
x
x
x
x
RO
x
5
x
x
SE
X
x
x
x
SI
X
x
x
SK
X
x
x
Total
21
8
8
-
12
5
19
7
Notes:
1: Austria and Iceland have not established rules regarding submission of notifications to issuers but have
described the informal market practice in this area.
2: Email notifications to the Italian National Competent Authority have to be performed by way of certified email
or email with an electronic signature.
3: Only in case the digital portal is unavailable due to technical problems.
4: Portugal has not established rules regarding submission of notifications to the National Competent
Authority or to issuers but has described the informal market practice in this area.
5: Email notifications have to include an incorporated extended electronic signature.
85
Table 9: Permitted formats for submitting notifications to NCAs and issuers
Word document
HTML
Readable PDF
Excel file
XML
BE
x
x
1
BG
x
CZ
x
x
ES
2
x
FR
x
x
IT
2
x
x
LT
x
x
NL
2
x
PT
3
x
x
x
Comment:
Only National Competent Authorities who have taken a position in this area are mentioned.
Notes:
1: The use of an excel file is only permitted for submitting notifications to the National Competent Authority.
2: The format rules apply only when submitting notifications to the National Competent Authority. When the
digital portal is unavailable due to technical problems, it is permitted to submit notifications in a non-readable
PDF.
3: Portugal has not established rules regarding the format for submission of notifications but have described the
informal market practice in this area.
Table 10: Deadline for publishing the notification
Same day as receipt
DK
1
, PL
One trading day after receipt
CY, IE
2
, LV, NL
3
Two trading days after receipt
AT, EL, HR,
Three trading days after receipt
BE, BG, CZ, DE, EE, ES, FR, IE
4
, IS, IT, LT, LU, MT, PT, RO, SI, SK,
Miscellaneous
FI
5
, HU
6
, NO
7
, SE
6
Notes:
1: From 1 January 2018, the deadline for publication will be three days after the notification is received.
2: Applicable to all issuers except non-Irish issuers and CEIFs.
3: The deadline for publishing the notification is on the trading day after the day on which the notification was
received by the NCA.
4: Applicable to non-Irish issuers and CEIFs.
5: Publication of the notification should be made as soon as possible; this will in most cases be on the day when
the notification is made but the issuer may delay publication in order to receive corrected or supplementary
information in relation to the notification.
6: The deadline for publishing the notification is two calendar days following receipt.
7: The notification must be published in an effective and non-discriminating manner; no deadline in terms of
days has been defined.