Key takeaways

• 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.