Reporting of short positions

Reporting of short positions and instructions on how to submit such notifications.

ESMA is temporarily lowering the notification threshold for natural or legal persons who has a net short position in a share admitted to trading on a regulated market. For more information please see the following links: press release and ESMA   

See guides on how to navigate in the notification system:

Reporting portal

Notifications must be made through the Danish FSA Database for company announcements. You can find the reporting portal here:

Danish Companies must use a digital signature to submit notifications. Foreign companies and foreign individuals who are not able to receive a digital signature can by contacting the Danish FSA get a username and password. See the guide above and further information below.

How to apply for user id and password if you are and foreign company or foreign individual

Applying for user name and access code Please use this link:

Before signing up you should have electronic copies of the below-mentioned documents (a, b and c) ready on your computer, making it easy for you to upload them during the registration process. Please submit the required documents together in one file. Furthermore, you need to have a valid, unique e-mail address (not previously used) which will be your personal user name for the system in the future. Once approved by the Danish FSA you will receive the password to the system. It will be sent to the email address that you have indicated. The approval is normally carried out on a daytoday basis on weekdays within normal Danish working hours.

Documents required:

  • a) A power of attorney empowering you to notify on behalf of the undertaking.
  • b) Proof of incorporation of the undertaking, by form of a transcript from the local business register (an Internet transcript is sufficient). Note: Under normal conditions, the transcript should not be back dated more than three months. However, due to the extra ordinary conditions in relating to the lowered reporting threshold, the Danish FSA will temporarily accept any valid proof of incorporation. If you are unable to retrieve a proof of incorporation within the reporting deadline, please contact the Danish FSA
  • c) A copy of your employee ID, passport, drivers licence or similar identification card
    It will be possible to issue a power of attorney to have another person submit a notification on short positions. The power of attorney must be registered by the Danish FSA before any notification can be submitted. For more information please see “the guide on how to assign a reporting party” above.

The specific solutions that are applicable today for lawyers and news distributors that allow them to report on behalf of clients will not be available for the reporting of short positions.

If you have any questions in relation to the registration process please contact the Danish FSA:

Reporting of net short position in shares

Companies or individuals who have a net short position of 0.2% of the issued share capital of a company admitted to trading on a regulated market or an MTF are obliged to give the Danish FSA notice of the short position. That Company or individual is then obligated to report changes in the short position of 0.1% of the issued share capital until the position is below 0.2%.

If a short position in shares rises above 0.5%, the short position is subject to public disclosure. Subsequent changes in the short position of 0.1% will also be published as long as the short position is more than 0.5%. The obligation to disclose is met when the notification of the short position is submitted to the FSA as part of the report will be made publicly available in the FSA database. This applies only to reports of short positions in shares exceeding 0.5% of the issued share capital.

Reporting of short position in sovereign debt

Companies or individuals who have a short position in Danish government bonds above a certain threshold value must report this to the Danish FSA. Subsequently, changes in the short position above a certain threshold value must be also reported, as long as the short position is above the threshold that triggers reporting obligation.

The two thresholds are set by ESMA website and will be updated quarterly.