Reporting of short positions

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

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). Please note: The transcript should not be more than 12 months old
  • 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 % in the issued share capital of an issuer with shares admitted to trading on a regulated market or an MTF in Denmark are required to give the Danish FSA notice of the net short position. Following a notice to the Danish FSA, the company or individual is then obligated to report changes to the net short position for every 0.1 %-point above the reporting threshold that the position crosses, until it goes below the 0.2 % threshold. That is, the company or individual shall notice the Danish FSA every time its net short position reaches or crosses 0.2 %, 0.3 %, 0.4 %, etc. of the issuer’s issued share capital.

Due to increased volatility on the financial markets in 2020 triggered by the COVID-19 pandemic, ESMA decided to temporarily lower the reporting threshold of 0.2 % to 0.1 % of an issuer’s issued share capital that has its shares admitted to trading on a regulated market, effective from 16 March 2020. The temporarily lowered reporting threshold of 0.1 % was effective until 19 March 2021, after which the reporting threshold was set back to 0.2 %.

If a company’s or indvidual’s net short position reaches or exceeds 0.5 % of an issuer’s issued share capital, the net short position must be made available to the public. Subsequent changes of 0.1 % to the net short position must also be published as long as the net short position is at or above 0.5 %. The obligation to make the net short position available to the public is automatically fulfilled when the net short position is reported to the Danish FSA, since parts of the short selling notification will be publicly available through the Danish FSA’s reporting system. This only applies to reported net short positions at or above 0.5 % of an issuer’s 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.