Flagging obligation

Flagging obligation refers to the obligation to notify major shareholdings and proportions of voting rights in accordance with Chapter 9 of the Finnish Securities Markets Act. The Finnish Securities Markets Act has been changed as of 19 April 2024 so that the obligation also applies to holdings and voting rights in companies traded in First North.

The purpose of the obligation is to provide investors with equal opportunities to have information on companies’ ownership structures and changes therein. A flagging notification shall be made whenever the proportion of holdings or votes in a listed company for a shareholder, or a person comparable to a shareholder, and/or holdings of controlled entities, reaches, exceeds, or falls below a disclosure threshold. The thresholds are 5%, 10%, 15%, 20%, 25%, 30%, 50%, 2/3 and 90% of the number of voting rights or shares in a company. 

A flagging notification to the company, as well as the Finnish Financial Supervisory Authority, shall be made as follows:

  1. Holdings exceeding a flagging threshold as of 19 April 2024
    In case a proportion of holdings or votes is at least five percent on 19 April 2024, as the change in regulation enters into force, such a holding has not previously been disclosed, a flagging notice shall be made within two months from the change in regulation, i.e. no later than 19 June 2024.
  2. Changes during the transition period 19 April – 19 June 2024
    In case a disclosure threshold has been reached, exceeded, or a holding falls below the threshold during the two-month transition period between 19 April – 19 June 2024, a flagging notification shall be made during this transition period, i.e. no later than 19 June 2024.
  3. Notifications after the transition period (as of 20 June 2024)
    As of 20.6.2024, flagging notifications must be made following normal rules without undue delay.

A shareholder must submit a flagging notification to the Financial Supervisory Authority using the flagging form available on the FIN-FSA’s website and send the notification to the company.  

Notification form

More information on the flagging obligation is available on FIN-FSA website at:

Flagging notifications to Fodelia Plc shall be sent by email to