Documentation

How European short position disclosures work

An overview of how public short selling disclosures work across European countries (EU and UK)

Unified disclosures

ShortsInsights brings public short-position disclosures from multiple European sources together in one page

Threshold-driven data

Public records are disclosed to the public when relevant threshold levels are reached or crossed

Updated daily

We update the dataset daily using public regulator disclosures so newly published threshold crossings can be tracked in one place across European markets

Net short positions in Europe and the regulatory framework

A net short position is the overall short exposure of a person or entity in relation to the issued share capital of a company after offsetting any long exposure held in the same issuer. In practical terms, the figure is not intended to describe one isolated trade. It is a regulatory calculation designed to capture a holder's net short exposure once relevant long and short positions have been taken into account, including positions created through derivatives and related instruments.

The modern European framework for public short position disclosures was shaped by the disruption of the 2008 financial crisis. As Regulation (EU) No 236/2012 explains, Member States responded with divergent emergency restrictions and disclosure measures, while the Union lacked a common framework. One of the purposes of the Regulation was therefore to reduce fragmentation, improve coordination across Member States, and introduce a more harmonised transparency regime for significant net short positions in European shares.

The Regulation also makes clear that short selling is not treated as inherently improper. In normal market conditions, it can contribute to market liquidity and price formation. The regulatory focus is instead on transparency, market confidence, and the ability of competent authorities to monitor significant positions that could create systemic risks, abusive behaviour, or disorderly markets.

For users of public short position data, this matters because the numbers published under the EU regime are regulatory disclosure figures, not a complete record of all short selling trading activity in a stock. They reflect the legal concept of a net short position under the Regulation, and they are shaped by specific reporting thresholds, calculation rules, and publication mechanics. That is why understanding the legal framework is essential before interpreting the data shown in public registers or on ShortsInsights.

Within the European Union, the main legal basis remains Regulation (EU) No 236/2012, commonly referred to as the Short Selling Regulation. In the United Kingdom, the EU framework no longer applies directly following Brexit in 2020, but the UK continues to operate its own separate short selling disclosure regime through the Financial Conduct Authority. In practice, both regimes remain highly relevant for anyone tracking publicly disclosed short positions across European markets.

Reporting and publication thresholds for net short positions

The European regime distinguishes between reporting to the relevant competent authority and publication to the market. That distinction is central to understanding why some short positions are visible publicly while others are not.

For shares admitted to trading on a trading venue in the European Union, a notification to the competent authority is required once a net short position in shares reaches 0.2% of the issued share capital of the company concerned, and again at each 0.1% step above that level. A public disclosure is required once the same net short position reaches 0.5% of the issued share capital, and again at each 0.1% step above that level.

This creates a two-tier transparency model. At the lower threshold, regulators receive information that allows them to monitor significant short activity and investigate potential risks or abusive conduct where necessary. At the higher threshold, the market receives information about significant individual net short positions through public disclosure.

In practical terms, this means that public registers do not show every reported position. A position can be reportable to the relevant authority without being visible to the public. For example, positions at 0.20%, 0.30% or 0.40% may trigger reporting obligations while still remaining below the public disclosure threshold. Public registers generally begin showing positions once they reach publication levels such as 0.50%, 0.60%, 0.70%, 0.80% and so on.

The same threshold logic also explains why movements within a band may not produce a new public entry. If a position changes but does not cross the next relevant threshold, the public register may remain unchanged even though the holder's actual exposure has moved. That is one of the key reasons why public short position datasets should be read as threshold-based disclosure datasets rather than full daily snapshots of every short position.

For readers using ShortsInsights, the practical takeaway is simple: if a position remains below the public threshold, it will usually not appear in the publicly available data shown on this site, even though regulatory reporting obligations may already have arisen at the authority level.

Example of threshold publication

Example

Reporting with authority starts at 0.20%, with public starting at 0.50%.

Tracked countries and their national authorities
AT: FMAIE: Central Bank of Ireland
BE: FSMAIT: CONSOB
CZ: CNBNL: AFM
DK: FinanstilsynetNO: Finanstilsynet
FI: FIN-FSAPL: KNF
FR: AMFPT: CMVM
DE: BaFinES: CNMV
GR: HCMCSE: FI
HU: MNBUK: FCA
IS: FME

When short positions are published

European net short position registers do not publish a full daily snapshot of every position. They publish disclosures when a position reaches, crosses, or falls below a relevant disclosure threshold.

This means a position can change from one day to the next without producing a new public entry, as long as it remains within the same disclosure band. For example, if a position moves between 0.63% and 0.67%, that movement would usually not trigger a new public disclosure because no new threshold has been crossed.

Under the EU framework, the net short position is calculated at the end of the trading day on which the position is held. The notification or disclosure must then be made on the following trading day within the applicable reporting deadline.

The FCA states that UK positions should be sent by 3:30pm on the trading day after the day the position was reached, with calculations made as at midnight on the trading day the position was reached. This timing is one reason why short-position registers are not real-time trading feeds.

The fragmentation of EU short position registers

There is no single EU-wide public net short position register that covers all Member States in one place. Public disclosures are made through national competent authorities such as BaFin, and each authority publishes its own data in its own format and on its own schedule.

That fragmentation is one of the main reasons ShortsInsights exists. ShortsInsights consolidates those public disclosures into a standardised view so that position holders, issuers, and changes can be followed more easily across European markets.

How does the United Kingdom fit in?

The United Kingdom is no longer part of the EU framework, but it continues to operate its own separate short selling disclosure regime through the Financial Conduct Authority.

In practical terms, the UK remains relevant for users tracking European short-position data because it still publishes public net short position disclosures under a broadly familiar threshold-based system, even though those disclosures now sit outside the EU framework.

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Sources

This page is based primarily on official materials from EUR-Lex and the Financial Conduct Authority.

This page is for general informational purposes only and does not constitute legal, regulatory, or investment advice. Please verify important details with the relevant authority or official source.