Issuers and investors

Notification of short positions

As of 27 September 2023, net short positions will be notified to the FIN-FSA via its electronic services. 

Who must notify net short positions?

The obligation to notify net short positions applies to all investors and market participants, where the net short position reaches, exceeds or falls below a certain threshold.

A net short position in the issued share capital of a company whose shares are subject to trading on a regulated market or on a multilateral trading facility (MTF) must be disclosed when the position reaches, exceeds or falls below the threshold of 0.1% of the company’s issued share capital. A new notification must be submitted for each 0.1 percentage point rise once the threshold has been breached.

A net short position relating to issued sovereign debt must also be notified when such a position reaches, exceeds or falls below the notification threshold. As regards debt issued by the Finnish government, the notification obligation arises when a position reaches, exceeds or falls below the threshold of 0.5% and each 0.25% above that.

When and how to notify?

The FIN-FSA must be notified of net short positions in shares listed on the Helsinki Stock Exchange and Finnish government bonds not later than at 3:30 pm on the following trading day after the transaction day.

Here's how to notify

The FIN-FSA has introduced its electronic services platform for reporting net short positions that requires strong authentication from users. To be able to report through the platform, foreign companies must register with Digital and Population Data Services Agency’s authorisation with an application service in Suomi.fi e-Authorisations portal.

Instructions are available on FIN-FSA website.

Publication of net short positions

Net short positions that have reached or exceeded the threshold of 0.5% of the issued share capital are published. 

Current net short positions

Historic net short positions

Related information

European Securities Market Authority (ESMA)

Regulation in the EUR-Lex service

  • Regulation (EU) No 236/2012 of the European Parliament and of the Council of 14 March 2012 on short selling and certain aspects of credit default swaps
  • Commission Delegated Regulation (EU) 2022/27 of 27 September 2021 amending Regulation (EU) No 236/2012 of the European Parliament and of the Council as regards the adjustment of the relevant threshold for the notification of significant net short positions in shares
  • Commission Delegated Regulation (EU) No 826/2012 of 29 June 2012 supplementing Regulation (EU) No 236/2012 of the European Parliament and of the Council with regard to regulatory technical standards on notification and disclosure requirements with regard to net short positions, the details of the information to be provided to the European Securities and Markets Authority in relation to net short positions and the method for calculating turnover to determine exempted shares
  • Commission Implementing Regulation (EU) No 827/2012 of 29 June 2012 laying down implementing technical standards with regard to the means for public disclosure of net position in shares, the format of the information to be provided to the European Securities and Markets Authority in relation to net short positions, the types of agreements, arrangements and measures to adequately ensure that shares or sovereign debt instruments are available for settlement and the dates and period for the determination of the principal venue for a share according to Regulation (EU) No 236/2012 of the European Parliament and of the Council on short selling and certain aspects of credit default swaps
  • Commission Implementing Regulation (EU) No 918/2012 of 5 July 2012 supplementing Regulation (EU) No 236/2012 of the European Parliament and of the Council on short selling and certain aspects of credit default swaps with regard to definitions, the calculation of net short positions, covered sovereign credit default swaps, notification thresholds, liquidity thresholds for suspending restrictions, significant falls in the value of financial instruments and adverse events
  • Commission Delegated Regulation (EU) No 919/2012 of 5 July 2012 supplementing Regulation (EU) No 236/2012 of the European Parliament and of the Council on short selling and certain aspects of credit default swaps with regard to regulatory technical standards for the method of calculation of the fall in value for liquid shares and other financial instruments