Thresholds Overview Module – Highwire Extensions

Major Shareholdings

Country	Rule	Disclosure Percentage																								Notes
		1	2	3	4	5	10	15	20	25	30	35	40	45	50	55	60	65	70	75	80	85	90	95	100
Austria	Major Shareholdings			3*	4	5	10	15	20	25	30	35	40	45	50					75			90			The threshold of 3% applies only to issuers which have stipulated this threshold value in their articles of association. A special condition for this to become effective is the publication of the relevant clause of the articles of association on the issuer’s website and a notification to the FMA.
Belgium	Major Shareholdings					5	10	15	20	25	30	35	40	45	50	55	60	65	70	75	80	85	90	95		Issuers may impose private notification thresholds
Bulgaria	Major Shareholdings					5	10	15	20	25	30	35	40	45	50	55	60	65	70	75	80	85	90	95
Croatia	Major Shareholdings					5	10	15	20	25	30				50					75
Cyprus	Major Shareholdings					5	10	15	20	25	30				50					75
Czech Republic	Major Shareholdings	1*		3*		5	10	15	20	25	30		40		50					75						The thresholds of 1% and 3% are "size adjusted" whereby the 3% threshold only applies to holdings in companies with share capital > 100m CZK and the 1% threshold only applies to holdings in companies with share capital > 500m CZK
Denmark	Major Shareholdings					5	10	15	20	25	33.33				50			66.66					90
Estonia	Major Shareholdings					5	10	15	20	25	33.33				50			66.66
Finland	Major Shareholdings					5	10	15	20	25	30				50			66.66					90			In Finland shareholders are required to notify both voting rights and shares.
France	Major Shareholdings					5	10	15	20	25	30	33.33			50			66.66					90	95		Issuers may impose private notification thresholds as low as 0.5%
Germany	Major Shareholdings			3*		5	10	15	20	25	30				50					75						The 3% threshold applies only for notifying voting rights (TD Art. 9/10), but not for positions arising out of financial instruments (TD Art. 13) or aggregated positions (TD Art. 13a
Greece	Major Shareholdings					5	10*	15	20	25	33.33				50			66.66								Shareholders who have crossed the 10% threshold are required to notify any increase or decrease in their holdings which is equal to or greater than 3%.
Hungary	Major Shareholdings					5	10	15	20	25	30	35	40	45	50					75	80	85	90	95
Iceland	Major Shareholdings					5	10	15	20	25	30	35	40		50			66.66					90
Ireland	Major Shareholdings (Irish Issuers except CEIFs)			3% and each 1% thereafter up to 100%
Ireland	Major Shareholdings (Non-Irish Issuers and CEIFs)					5	10	15	20	25	30				50					75
Italy	Major Shareholdings	1*		3*		5	10	15	20	25	30				50			66.66					90			The threshold of 1% is a temporary threshold applicable to a list of non-SME companies. The 3% threshold is regularly applicable only to holdings in non-SME companies.
Latvia	Major Shareholdings					5	10	15	20	25	30				50					75			90	95
Lithuania	Major Shareholdings					5	10	15	20	25	30				50					75				95
Luxembourg	Major Shareholdings					5	10	15	20	25	33.33				50			66.66
Malta	Major Shareholdings					5	10	15	20	25	30				50					75				95
Netherlands	Major Shareholdings			3		5	10	15	20	25	30		40		50		60			75				95
Norway	Major Shareholdings					5	10	15	20	25	33.33				50			66.66					90
Poland	Major Shareholdings					5	10	15	20	25	33.33				50					75			90
Portugal	Major Shareholdings		2			5	10	15	20	25	33.33				50			66.66					90
Romania	Major Shareholdings					5	10	15	20	25	33.33				50					75
Slovakia	Major Shareholdings					5	10	15	20	25	30				50					75
Slovenia	Major Shareholdings					5	10	15	20	25	33.33				50					75
Spain	Major Shareholdings	1*		3		5	10	15	20	25	30	35	40	45	50		60		70	75	80		90			Spain has put in place specific notification thresholds for shareholders which are residents in tax havens, nil tax countries or countries with which no effective exchange of tax information is in place; such shareholders have to notify each time they reach/cross a 1% threshold.
Sweden	Major Shareholdings					5	10	15	20	25	30				50			66.66					90			In Sweden shareholders are required to notify both voting rights and shares.
Switzerland	Major Shareholdings			3		5	10	15	20	25		33.33			50			66.66
United Kingdom	Major Shareholdings (UK Issuers)			3% and each 1% thereafter up to 100%
United Kingdom	Major Shareholdings (UK Issuers - Fund Managers)					5	10	10% to 100% at 1% increments
United Kingdom	Major Shareholdings (Non-UK Issuers)					5	10	15	20	25	30				50					75
Canada	Major Shareholdings (Early Warning Reporting)						10% and changes of 2% thereafter																			2% changes are swinging thresholds
Canada	Major Shareholdings (Alternative Monthly Reporting)						10% and changes of 2.5% thereafter																			2.5% changes are hard thresholds
Canada	Major Shareholdings (SEDI - Insider Reporting)						10% and every transaction involving any security of the issuer whilst an insider
United States	Major Shareholdings (Schedule 13D)			5% and changes of 1% thereafter																						Schedule 13D reports the acquisition and other information within ten days after the purchase. Amendments to Schedule 13D should be filed “promptly” to report material changes in the information disclosed. For example, material changes include, but are not limited to, an acquisition or disposition of beneficial ownership of 1% or more of the class of securities and any other changes that a reasonable investor would consider important to their decision to buy or sell the security in question.
United States	Major Shareholdings (Schedule 13G: Qualified Institutional Investor)					5-10		10% and changes of 5% thereafter																		1. Qualified Institutional Investors only report their greater than 5% positions held as of the close of the calendar year either in an initial report or in an amendment in the case of any change in the information provided. 2. However, if prior to the end of the calendar year the Qualified Institutional Investor owns more than 10% as of the close of any month, a Schedule 13G must be filed or amended within 10 calendar days reporting the holdings as of the close of the month. 3. After crossing the 10% threshold, Qualified Institutional Investors must file an amendment to their Schedule 13G within 10 calendar days following the close of the month to report any ownership change of 5% or more as of the close of the month.
United States	Major Shareholdings (Schedule 13G: Passive Investor )					5	10	10% and changes of 5% thereafter																		Initial An initial Schedule 13G must be filed within 10 calendar days of crossing the 5% threshold (instead of within 45 calendar days after calendar year end). Amendments 1. An amendment is required to be filed promptly on crossing the 10% threshold (instead of within 10 calendar days following the close of the month). 2. After crossing the 10% threshold, prompt amendments are required every time the Passive Investor increases or decreases ownership by 5% (instead of within 10 calendar days following the close of the month).
Australia	Major Shareholdings					5% and changes of 1% thereafter																				1% changes are swinging thresholds
Brazil	Major Shareholdings					5% and changes of 5% thereafter																				5% changes are swinging thresholds
Hong Kong	Major Shareholdings					5 to 100% at 1% increments
India	Major Shareholdings					5% and changes of 2% thereafter																				NB. 10% initial threshold for issuer listed on Innovators Growth Platform with subsequent disclosure required for 5% changes.
Indonesia	Major Shareholdings					5% and any subsequent changes of ownership of at least 0.5%
Israel	Major Shareholdings					5% and any further sales or purchases of shares
Japan	Major Shareholdings					5% to 100% at 1% changes																				1% changes are swinging thresholds
New Zealand	Major Shareholdings					5% and changes of 1% thereafter																				1% changes are swinging thresholds
South Africa	Major Shareholdings					5	10	15	20	25	30	35	40	45	50	55	60	65	70	75	80	85	90	95	100
Turkey	Major Shareholdings					5	10	15		25	33				50			66						95
Bermuda	Major Shareholdings	Curently no major shareholder disclosure regime in place
Colombia	Major Shareholdings	Curently no major shareholder disclosure regime in place
Gibraltar	Major Shareholdings	Curently no major shareholder disclosure regime in place
Guernsey	Major Shareholdings	Curently no major shareholder disclosure regime in place
Isle of Man	Major Shareholdings	Curently no major shareholder disclosure regime in place
Jersey	Major Shareholdings	Curently no major shareholder disclosure regime in place
Kazakhstan	Major Shareholdings	Curently no major shareholder disclosure regime in place																								A person independently or jointly with affiliated persons, who intends to acquire 30% or more of the voting shares of a company is obligated to notify the company and the NBK of such intention.
Marshall Islands	Major Shareholdings	Curently no major shareholder disclosure regime in place
Monaco	Major Shareholdings	Curently no major shareholder disclosure regime in place
Namibia	Major Shareholdings	Curently no major shareholder disclosure regime in place																								Beneficial ownership and shareholding in excess of 5% in banking institutions must be reported to the Bank of Namibia by the particular banking institution.
Panama	Major Shareholdings	Curently no major shareholder disclosure regime in place
Peru	Major Shareholdings	Curently no major shareholder disclosure regime in place																								SMV, the local securities market regulator, requires local companies (listed) to disclose its shareholders with more than 0.5% participation each quarter. There are no reporting requirements on behalf of shareholders.
Puerto Rico	Major Shareholdings	Curently no major shareholder disclosure regime in place
Qatar	Major Shareholdings	Curently no major shareholder disclosure regime in place
Uganda	Major Shareholdings	Curently no major shareholder disclosure regime in place																								Any shareholding of more than 5% in a financial institution must be disclosed to the Central Bank
Uruguay	Major Shareholdings	Curently no major shareholder disclosure regime in place
Venezuela	Major Shareholdings	Curently no major shareholder disclosure regime in place
Virgin Islands, British	Major Shareholdings	Curently no major shareholder disclosure regime in place
Zimbabwe	Major Shareholdings	Curently no major shareholder disclosure regime in place
Singapore	Major Shareholdings					5% to 100% at 1% increments
Russia	Major Shareholdings					5	10	15	20	25	30				50					75				95
China	Major Shareholdings					5% and subsequent increase or decrease of 5%
China	Major Shareholdings					5% and subsequent increase or decrease of 1%
Ukraine	Major Shareholdings					5	10	15	20	25	30				50					75				95
Thailand	Major Shareholdings					5	10	15	20	25	30	35	40	45	50	55	60	65	70	75	80	85	90	95
UAE	Major Shareholdings					5% to 100% at 1% increments
Egypt	Major Shareholdings					5	10	15	20	25	30	35	40	45	50	55	60	65	70	75	80	85	90	95		NB. Board members or employees acquiring 3% (or further multiples of 3%) must disclose.
Argentina	Major Shareholdings					5	10	15	20	25	30	35	40	45	50	55	60	65	70	75	80	85	90	95		Listed companies' controlling shareholders must disclose their share ownership. They must inform the CNV, before the 15th of each month, of any changes during the previous month in their holdings, using designated informative forms.
Malaysia	Major Shareholdings					5% and any change thereafter
Chile	Major Shareholdings						10% and any change thereafter
Mexico	Major Shareholdings	1*					10% and 5% changes																			Any natural person who owns or receives 1% or more of the issuer's capital, directly or indirectly, through one or more legal persons, trusts or other investment vehicles, shall report such situation to the issuer annually using Annex V, by 15 May.
Liechtenstein	Major Shareholdings					5	10	15	20	25	33.33				50		66
Bahamas	Major Shareholdings						10
Barbados	Major Shareholdings						10% and any trade																			A shareholder who owns 10 per cent or more of the shares of a listed company shall declare every trade of those shares to the Exchange within one week of each such trade. Additionally, Where a person directly or indirectly acquires 25 per cent or more of the equity of a company, that person shall deliver by registered mail to the Regulator and to the company at its registered office or principal place of business within 24 hours of the acquisition, a written statement
Cayman Islands	Major Shareholdings									25
Morocco	Major Shareholdings					5	10		20		33.33				50			66.66
Philippines	Major Shareholdings					5	10% and any change thereafter
South Korea	Major Shareholdings					5% and subsequent increase or decrease of 1%
Sri Lanka	Major Shareholdings						10																			Any person or persons acting in concert with such person who acquire or hold ten per centum or more of the shares or voting rights of a company shall report their holdings to such company, the Commission and the Stock Exchange within two market days of such acquisition.
Taiwan	Major Shareholdings						10% and 1% increments
Vietman	Major Shareholdings					5% and each 1% thereafter up to 100%

Short Selling

Country	Rule	Thresholds
Australia	Short Selling Reporting	0.01% or the value of the position is AUD 100,000
Europe	Short Selling Reporting	0.1% and 0.1% increments
Hong Kong	Short Selling Reporting	The lower of HK$30 million and 0.02% of the value of the total number of Designated Securities issued by the issuer.
United Kingdom	Short Selling Reporting	0.1% and 0.1% increments
Singapore	Short Selling Reporting	0.2% of total issued shares in the relevant class of shares or units; or S$ 2,000,000.
Japan	Short Selling Reporting	0.2% and 0.1% increments
South Korea	Short Selling Reporting	0.01% (and > KRW 100m) of outstanding listed shares
India	Short Selling Reporting
Israel	Short Selling Reporting
Kenya	Short Selling Reporting
Argentina	Short Selling Reporting	Curently no short selling disclosure regime in place
Bahamas	Short Selling Reporting	Curently no short selling disclosure regime in place
Bahrain	Short Selling Reporting	Curently no short selling disclosure regime in place
Bangladesh	Short Selling Reporting	Curently no short selling disclosure regime in place
Bermuda	Short Selling Reporting	Curently no short selling disclosure regime in place
Botswana	Short Selling Reporting	Curently no short selling disclosure regime in place
Brazil	Short Selling Reporting	Curently no short selling disclosure regime in place
Canada	Short Selling Reporting	Curently no short selling disclosure regime in place
Cayman Islands	Short Selling Reporting	Curently no short selling disclosure regime in place
Chile	Short Selling Reporting	Curently no short selling disclosure regime in place
China	Short Selling Reporting	Curently no short selling disclosure regime in place
Colombia	Short Selling Reporting	Curently no short selling disclosure regime in place
Curacao	Short Selling Reporting	Curently no short selling disclosure regime in place
Ecuador	Short Selling Reporting	Curently no short selling disclosure regime in place
Egypt	Short Selling Reporting	Curently no short selling disclosure regime in place
Ghana	Short Selling Reporting	Curently no short selling disclosure regime in place
Gibraltar	Short Selling Reporting	Curently no short selling disclosure regime in place
Guernsey	Short Selling Reporting	Curently no short selling disclosure regime in place
Indonesia	Short Selling Reporting	Curently no short selling disclosure regime in place
Isle of Man	Short Selling Reporting	Curently no short selling disclosure regime in place
Jamaica	Short Selling Reporting	Curently no short selling disclosure regime in place
Jersey	Short Selling Reporting	Curently no short selling disclosure regime in place
Jordan	Short Selling Reporting	Curently no short selling disclosure regime in place
Kazakhstan	Short Selling Reporting	Curently no short selling disclosure regime in place
Kuwait	Short Selling Reporting	Curently no short selling disclosure regime in place
Lebanon	Short Selling Reporting	Curently no short selling disclosure regime in place
Malaysia	Short Selling Reporting	Curently no short selling disclosure regime in place
Marshall Islands	Short Selling Reporting	Curently no short selling disclosure regime in place
Mauritius	Short Selling Reporting	Curently no short selling disclosure regime in place
Mexico	Short Selling Reporting	Curently no short selling disclosure regime in place
Monaco	Short Selling Reporting	Curently no short selling disclosure regime in place
Morocco	Short Selling Reporting	Curently no short selling disclosure regime in place
Namibia	Short Selling Reporting	Curently no short selling disclosure regime in place
New Zealand	Short Selling Reporting	Curently no short selling disclosure regime in place
Nigeria	Short Selling Reporting	Curently no short selling disclosure regime in place
Oman	Short Selling Reporting	Curently no short selling disclosure regime in place
Pakistan	Short Selling Reporting	Curently no short selling disclosure regime in place
Panama	Short Selling Reporting	Curently no short selling disclosure regime in place
Papua New Guinea	Short Selling Reporting	Curently no short selling disclosure regime in place
Peru	Short Selling Reporting	Curently no short selling disclosure regime in place
Philippines	Short Selling Reporting	Curently no short selling disclosure regime in place
Puerto Rico	Short Selling Reporting	Curently no short selling disclosure regime in place
Qatar	Short Selling Reporting	Curently no short selling disclosure regime in place
Russia	Short Selling Reporting	Curently no short selling disclosure regime in place
Saudi Arabia	Short Selling Reporting	Curently no short selling disclosure regime in place
Serbia	Short Selling Reporting	Curently no short selling disclosure regime in place
South Africa	Short Selling Reporting	Curently no short selling disclosure regime in place
Sri Lanka	Short Selling Reporting	Curently no short selling disclosure regime in place
Switzerland	Short Selling Reporting	Curently no short selling disclosure regime in place
Thailand	Short Selling Reporting	Curently no short selling disclosure regime in place
Tunisia	Short Selling Reporting	Curently no short selling disclosure regime in place
Turkey	Short Selling Reporting	Curently no short selling disclosure regime in place
Uganda	Short Selling Reporting	Curently no short selling disclosure regime in place
Ukraine	Short Selling Reporting	Curently no short selling disclosure regime in place
United Arab Emirates	Short Selling Reporting	Curently no short selling disclosure regime in place
Uruguay	Short Selling Reporting	Curently no short selling disclosure regime in place
Venezuela	Short Selling Reporting	Curently no short selling disclosure regime in place
Virgin Islands, British	Short Selling Reporting	Curently no short selling disclosure regime in place
Zimbabwe	Short Selling Reporting	Curently no short selling disclosure regime in place

Takeovers

Country	Rule	Intial Threshold	Increment	Rule Narrative	Takeover Table
Australia	Takeover Dealing Disclosure	5%	1% changes	If a takeover bid is on foot, the period for giving substantial holding notices is reduced – notices in relation to all interests of the bidder and its associates in the target must be provided by 9.30am on the next trading day.
Austria	Takeover Dealing Disclosure	3%	Any change	In the course of a public offer, shareholders who hold at least three percent of the voting rights of the offeree company (qualified shareholders) have specific rights and obligations during the period of the offer. From the date of the publication of an offer (pre-announcement or offer prospectus) until the end of the additional acceptance period, qualified shareholders have the obligation to report all transactions in the equity securities and in related equity derivatives of the offeree company or the company whose securities are being offered in exchange.	https://www.takeover.ch/transactions/shareholders
Belgium	Takeover Dealing Disclosure	1%	Any change
Canada	Takeover Dealing Disclosure	5%	0.02	EWR disclosure threshold is reduced to 5% when a takeover bid by another party or an issuer bid is outstanding
Cyprus	Takeover Dealing Disclosure	%	Any change	Any transaction during the takeover bid period involving shares of the target by the bidder or any other persion holding 5% of the target's voting rights must be disclosed immediately. Any person who acquires 0.5% of the share capital of the bidder or ther target must immediately disclosure that transaction and all previous transactions involving such shares.
Cyprus	Takeover Dealing Disclosure	0.5%	0.005	Any transaction during the takeover bid period involving shares of the target by the bidder or any other persion holding 5% of the target's voting rights must be disclosed immediately. Any person who acquires 0.5% of the share capital of the bidder or ther target must immediately disclosure that transaction and all previous transactions involving such shares.
France	Takeover Dealing Disclosure	5%		Enhanced disclosure obligations apply to holdings of 5% (or 1% for holdings acquired since the start of the pre-offer period). If holdings have increased by 2% or more since the start of the pre-offer period, report objectives intended to be pursued to the AMF.
France	Takeover Dealing Disclosure	1% increase
Greece	Takeover Dealing Disclosure	5%	Any change	Any acquisition, by the offeror or by natural legal entities, holding 5% of the voting rights of the offeree or offerror (if securities exchange offer).
Greece	Takeover Dealing Disclosure	0.5%	0.005	Increases in positions by 0.5% in the voting rights of the offerree or offerror (if securities exchange offer)since the begining of the takeover.
Hong Kong	Takeover Dealing Disclosure	5%	All dealings
Ireland	Takeover Dealing Disclosure	1%	All dealings
Spain	Takeover Dealing Disclosure	1%	3% and any dealing	In the context of a takeover bid, the following transactions have to be publicly disclosed: • any acquisition reaching or exceeding 1% of the target company’s voting rights; and • any increase or decrease in the stake held by holders of 3% or more of the voting rights in the target company.
Switzerland	Takeover Dealing Disclosure	3%	All dealings
United Kingdom	Takeover Dealing Disclosure	1%	All dealings