Who are subject to the disclosure obligation?  

The obligation to disclose holdings applies to shareholders of listed companies and persons comparable to shareholders, as well as to the listed company itself.

Shareholders must notify both the listed company and the FSA of changes in their holdings when their holdings exceed, fall below or reach the disclosure thresholds in respect of voting rights or shares held in the company.

Alongside shareholders, the disclosure obligation may also apply to persons comparable to shareholders who either directly or indirectly exercise the managing and asset rights conferred by a holding. This refers to persons who are not themselves shareholders in the company but who exercise control over a shareholding company, and, in some cases, to asset managers, fund management companies and trustees. Persons comparable to shareholders also have an obligation to notify both the listed company and the FSA of changes in holdings.

Listed companies have an obligation to publicly disclose the shareholder's notification. The company makes the information available to the regulated market.