The Danish FSA changes the filing requirements for major shareholder and PDMR notifications

New filing procedure

Under the current system, major shareholder and PDMR notifications are submitted via a form uploaded to the OAM system. In practice, issuers use a news distributor to make an announcement which is then automatically filed in the OAM system via the system. Going forward, disclosures will be submitted directly through the Danish FSA's website, rather than by upload of the filled-out form. The change will be implemented on 1 December 2025.

It will still be possible to download the completed filing after submission, allowing stakeholders to forward the notification to the issuer.

The Danish FSA's announcement does not specifically clarify whether the current PDMR disclosure process - where the obligation is deemed fulfilled through the issuer's market announcement - will remain unchanged, or whether the requirement to submit a PDMR filing directly in the OAM system will be reinstated. The practical implication of such reinstatement will be that the PDMR will have to make both a disclosure to the issuer as well as the Danish FSA.  In any case, the issuer will remain responsible for submitting the PDMR disclosure through a market announcement.

We recommend that issuers contact their selected news distributor to clarify the practical implications of these changes. 

Other disclosure obligations and filing formats remain unchanged.

Temporary system closure

The OAM filing system will be closed from 26 November until 1 December 2025 due to scheduled maintenance and system updates. Consequently, it will not be possible to make any filings during this period.

The Danish FSA urges all stakeholders with filing obligations during the closure period to submit their filings as soon as possible after the system reopens on 1 December 2025 at 08:00 AM CET.

Read the Danish FSA's article about the temporary system closure

Upcoming replacement of the OAM system

Finally, stakeholders should note that the European Single Access Point (ESAP) legislation will enter into force on 10 June 2026, at which time the OAM filing system will be replaced.

For more capital markets law updates, see Plesner's LinkedIn-page: Plesner Capital Markets Update