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 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.

Reporting Portal

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

Danish Companies must use a digital signature to submit notifications. Foreign companies and 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.

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.

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