Denmark – FSA Major Shareholding Disclosure Form

Denmark – FSA Major Shareholding Disclosure Form

On 12 April 2021, DEN FSA issued report on errors in use of standard form.

  • DEN FSA issued a report on the use and completion of the new standard form for major shareholding reporting, which was introduced on 8 October 2019, and is subject to mistakes.


  • DEN FSA examined how many major shareholders reported announcements to its reporting system, OASM, from 9 October 2019 to 9 April 2020, using the standard form.
  • It also examined how many errors occurred in the use of the standard form.


  • A major shareholder has a duty to notify issuers and submit the standard form for reporting major shareholding to DEN FSA when shareholding changes.
  • This means it constitutes, exceeds or falls below 5, 10, 15, 20, 25, 50 or 90 per cent, and a third or two-thirds of voting rights or share capital of company listed on market.
  • The purpose of major shareholding rules is to ensure equal access for investors and issuers for information on who controls any companies trading on the regulated market.
  • It also covers financial instruments, based on shares, which have an economic effect that equates with the effect of financial instruments, whether or not shares are acquired.

Information Required

  • The standard form must contain any and all changes in voting rights and share capital, including shares that would affect the distribution of voting rights rights in a company.
  • The date for when the limits that are set in law are reached or no longer applicable.
  • The identity of a major shareholder, whether or not he is entitled to exercise rights and the identity of natural or legal person entitled to exercise voting rights on their behalf.
  • An indication of the chain of controlled companies through which the voting rights are held, if the shares or financial instruments are held as a part of any core conditions.
  • Major shareholder's holding, even if they are not entitled to exercise the voting rights.

New Standard Form

  • The purpose of the form is to address some inconveniences in the previous standard form and try to remedy errors by creating clarity on some parts of the statement of holdings.
  • The structure of parts of the form has been amended so sections of the standard statement of holdings no longer require slitting into either shares and voting rights.
  • The text on some of the fields has been changed as it caused confusion in some reports.
  • This applies, for example, to the fields during the calculation of voting rights and tie holdings, which in the previous standard form has been named Direct and Indirect.
  • DEN FSA now also requires major shareholding disclosures to provide the address, e-mail address, and national ID number to adequately identify all the individual major shareholders.