Sweden – FI Fines for Late Substantial Shareholding Disclosure

Sweden – FI Fines for Late Substantial Shareholding Disclosure

On 16 September 2021, SWE FI fined Starbreeze SEK 250,000 for late shareholding disclosure.

  • SWE FI issued SEK 250,000 penalty fee against Starbreeze AB for late notifications, under the Act (2016:1306) and violating EU Market Abuse Regulation (Mar) provisions.
  • Follows SWE FI March 2020, fined Starbreeze AB for late substantial shareholding reporting.


  • Investigation and ongoing supervision found Starbreeze submitted late notifications regarding postponed publication of inside information pursuant to Article 17(4), March.
  • Company did not immediately inform SWE FI after inside information was made public.
  • On 19 September 2019, SWE FI sent letter presenting observations/preliminary assessment.
  • Starbreeze responded on 26 September 2019; SWE FI wrote again on 5 May 2021, stating it was considering intervention; Starbreeze responded again on 24 May 2021.


  • Starbreeze infringed deferred disclosure requirements by not immediately inform that publication of information had been postponed; some delays were long, others short.
  • SWE FI decided infringements should incur charges between SEK 10,000-40,000, with total fee of SEK 290,000, but in light of Covid, reduced this to SEK 250,000.

Next Steps

  • Starbreeze AB is able to appeal the decision.