FAQ about OAM and ESAP
When will the Danish FSA be ready with an updated version of OAM adapted to the ESAP requirements?
The DFSA introduced an updated version of OAM adapted to the requirements of ESAP Phase 1 on 28 September. This means that submissions covered by ESAP have been forwarded to ESAP since 28 September.
However, the forwarding of prospectus-related documents to ESAP is awaiting updates from ESMA, which are expected to be in place by February 2027.
Which submissions are covered by ESAP phase 1?
In practice, ESAP phase 1 means that certain information must be reported in accordance with EU legislation. Examples include:
- Short Selling Regulation (SSR):
Covers notifications of net short positions exceeding 0.5% of the issued share capital in the relevant company, cf. SSR Article 6(1). In addition, investment managers must submit a new notification if a position is increased or reduced and thereby reaches a new 0.1% threshold above 0.5%. - Transparency Directive (TD):
Includes periodic financial information, issuer notifications regarding major shareholders, information on home Member State, payments to authorities, number of voting rights and share capital, and changes to rights attached to securities. In addition, certain information prepared under the Market Abuse Regulation (MAR), such as “inside information” and issuers’ disclosure of “transactions by persons discharging managerial responsibilities”, also falls under the definition of “regulated information” in the Transparency Directive (TD) when published by listed companies, and is therefore included in ESAP phase 1. - Prospectus Regulation (PR):
Submission of prospectus-related documents, including base prospectuses, final terms, supplements, exemption documents, etc.
ESAP phase 2 is expected to start in January 2028, and ESAP phase 3 in January 2030, with additional directives and regulations gradually being added. The Danish FSA’s website will be updated on an ongoing basis.
Does ESAP mean that additional data must be included in OAM submissions?
ESAP requires new reference data for issuers to be included for submissions covered by ESAP. Reference data only needs to be updated once in the issuer’s user profile in OAM and will be automatically forwarded to ESAP with the submission.
Reference data includes, for example, information on industry sector, issuer size, and LEI code.
There will be no changes to login, and the platform as a whole will remain the same.
A significant change is that submitted data will be structurally validated before being forwarded to ESAP. If validation fails, the reporting entity will receive an email indicating that errors must be corrected.
Where can I find guidance on reporting under ESAP phase 1?
Download the guide to reporting in OAM and on submissions covered by ESAP Phase 1: Submission of announcements and notifications to the Danish FSA via the OAM system
Which file types and formats can be submitted in OAM adapted to ESAP?
ESAP requires that documents must be data-extractable. Some formats must also be machine-readable, meaning that these formats are structured so that software applications easily can identify, recognise, and extract specific data, including individual factual information and its internal structure (xBRL files).
List of file formats and reporting areas:
- Submissions under the Prospectus Regulation: PDF, XBRL, XHTML, ZIP
- Submissions under the Short Selling Regulation: no files
- Submissions under the Transparency Directive:
- Half-yearly and annual reports under Annual report: ESEF ZIP, XHTML, ZIP containing XHTML, images and text
- Other submissions: PDF, HTML, XHTML, ZIP containing XHTML, images and text
Where can I read more about ESAP?
We have provided a brief description of ESAP in this article:
European Single Access Point (ESAP) – the EU’s common portal for investors
Read more about ESAP on the EU’s website:
Transparency requirements for listed companies
Who maintains master data in OAM?
The issuer is responsible for maintaining own master data in OAM.
The system requires several master data fields to be provided when creating a profile. These are used when forwarding information to ESAP, including:
- User information, including the name, email address and telephone number of the person reporting on behalf of a company. The user will also be assigned a unique ID.
- Basic company information, including the company’s name, CVR number, country and email address. The company will also be assigned a unique ID.
- Extended company information, including LEI code, country of registered office, address, home Member State, host Member State, industry sectors, NACE codes, company size, etc.
Please note that information about company size may vary depending on the legal act under which the submission is made.
Where can I find more information about ESAP master data?
For information on industry sectors and company size, further details can be found in Commission Delegated Regulation (EU) 2025/1338.
Please note that information about company size may vary depending on the legal act under which the submission is made.
Information on NACE classification can be found in the relevant EU regulation: Commission Delegated Regulation (EU) 2023/137
What happens to notifications submitted in OAM but not forwarded to ESAP?
Notifications from major shareholders and persons discharging managerial responsibilities will continue to be submitted to the Danish Financial Supervisory Authority as before. These notifications will still not be published and will not be forwarded to ESAP.
Notifications covered by the Market Abuse Regulation and the Takeover Directive will be published in the OAM portal on the Danish FSA's website.
How are prospectus-related documents submitted in OAM/ESAP?
The Danish FSA ensures that approved prospectuses are submitted in OAM.
Once an issuer has had a prospectus approved by the DFSA, the issuer must publish the prospectus to the market and on the company’s website. Once the issuer has published the prospectus, the issuer must inform the DFSA. The DFSA will then publish the prospectus in OAM as soon as possible.
Issuers should note that if they use a service provider to publish the prospectus to the market, the service provider may have a function for sending the prospectus to the DFSA. This function should not be enabled, as OAM cannot receive the prospectus and the submission to the DFSA, and publication to the market is likely to result in an error message.
Service providers’ systems may differ. If the issuer needs assistance with this, the issuer should contact its service provider, not the DFSA.
The DFSA submits prospectus-related documents, including base prospectuses and supplements, in OAM and also submits them to ESMA’s prospectus register and ESAP. Issuers should continue to submit final terms in OAM, after which the DFSA will forward them to ESMA’s prospectus register and ESAP.