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Germany Tightens Voting Rights Disclosure Regime and Steps Up Sanctions
2 December 2015
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Complex new regime requires, e.g., earlier notifications, close monitoring of total number of outstanding shares, notification of cash-settled instruments on a delta-adjusted basis and use of new mandatory notification form.
Status notifications to be made by 15 January 2016 for all shareholdings which become notifiable as a result of the new regime and for ALL holdings of instruments representing at least 5% of the voting rights of an issuer.
Drastic new sanctions in case of violations, in particular, extended loss of shareholder rights, significantly increased fines and public naming and shaming.
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