Disclosures of capital, control and short positions

AFM Portal 

The AFM is currently developing new reporting forms in the AFM Portal. These include forms for the following reporting obligations:

• Notifications of net short positions
• Notifications concerning the disclosure of inside information 
• Notifications of substantial holdings and gross short positions
• Notifications of issued capital
• Notifications of home Member State 
• Notifications by persons discharging managerial responsibilities and persons closely associated with them

The AFM expects to make these forms available in the AFM Portal in the fourth quarter of 2026. From that point onwards, it will no longer be possible to submit notifications through the AFM Loket or by email. 

How do you submit a notification? 

You can use the AFM Portal to submit notifications on your own behalf, on behalf of another natural person, or on behalf of an organisation. A personal account is always required. Instructions for creating an account can be found on the AFM Portal landing page.

A mandate is required to submit notifications on behalf of another natural person or an organisation. If you need to act on behalf of an organisation that has not yet been registered in the AFM Portal, you must complete the ‘Link Organisation’ registration process. If the organisation has already been registered, you only need to be authorised and linked to that organisation.

When submitting a notification on your own behalf or on behalf of another natural person, select the personal context. No link to an organisation is required for this purpose. For notifications relating to net short positions, gross short positions and substantial holdings, you can submit a notification directly from your personal context. For other types of notifications, the available context depends on the type of notification and the role in which you are submitting it.

The following steps apply to all notifications:

1. Log in to the AFM Portal.
2. Go to Statutory notifications.
3. In the purple bar, go to Notifications and select the relevant form. 

Submitting a notification on behalf of an organisation

1. Select the relevant organisation in the purple bar.
2. In the purple bar, go to Notifications and select the relevant form. Is your organisation not listed in the menu? If so, you are not authorised to submit notifications on behalf of this organisation. The organisation’s authorisation administrator can grant you the ‘Capital markets notifications’ authorisation. Instructions for granting authorisations are available on the AFM Portal landing page. 

Submitting a notification on your own behalf

1. Select your personal context in the purple bar.
2. In the purple bar, go to Notifications and select the relevant form.

Authorising someone to submit notifications on your behalf 

To allow someone to submit notifications on your behalf, you must first authorise that person.

1. Select your personal context in the purple bar.
2. Click My AFM.
3. Go to Personal context authorisation and add the email address of the person who may submit notifications on your behalf. This person must have an AFM Portal account.

Submitting a notification on behalf of another natural person

1. Select your personal context in the purple bar.
2. In the purple bar, go to Notifications and select the relevant form.
3. In the form, indicate that you are submitting the notification on behalf of another natural person.

Transmission to the European Single Access Point (ESAP) 

The AFM transmits data from notifications to ESAP. For this reason, the AFM may in certain cases request additional identifying information, such as a Legal Entity Identifier (LEI). The AFM also supplements notification data with information required for the processing and publication of information through ESAP. 

Questions about transparency notifications: melden@afm.nl 

Questions about the disclosure of inside information: marketsupervision@afm.nl