Stand:updated on 17.06.2025 | Topic Major holdings of voting rights Notifications of Major Holdings (Sec. 33 et seq. WpHG)
Under section 33 et seq. of the German Securities Trading Act (Wertpapierhandelsgesetz – WpHG), persons whose direct or attributed holdings of voting rights and/or instruments reach or cross certain thresholds must report this to the issuer and BaFin using the mandatory reporting template (section 12 (1) of the German Securities Trading Reporting Regulation (Wertpapierhandelsanzeigeverordnung – WpAV)).
Electronic submission of voting rights notifications
Notifications of changes in major holdings of voting rights must be submitted electronically to BaFin and the company concerned. BaFin's reporting and publishing platform, the MVP, must be used to submit notifications electronically to BaFin.
Notifying parties can use the online form in the “Notifications of major holdings (section 33 et seq. of the WpHG)” specialised procedure to submit voting rights notifications electronically. The online form provides guidance on completing a number of the fields. Alternatively, an XML-based voting rights notification that has been created in line with BaFin’s requirements can be submitted electronically using BaFin’s SOAP web service or uploaded. Please see the “Additional information” section below for further details.
Such electronic voting rights notifications are designed in particular to make their publication easier for issuers. In line with this, the German Voting Rights Notification Regulation (Stimmrechtsmitteilungsverordnung – StimmRMV), which defines the electronic reporting procedure in greater detail, sets out specific requirements for the electronic submission of voting rights notifications to issuers: issuers must receive both a “readable” file format and an XML version of the voting rights notification, which they can use for publication. Notifying parties receive the voting rights notification that can be used to submit the notification electronically to the issuer in their MVP user account in the form of a zip file along with the confirmation that their voting rights notification has been successfully submitted to BaFin. Voting rights notifications pursuant to sections 33 et seq. of the WpHG only take legal effect once they have been submitted to both the issuer and BaFin.
Once you have registered to use the MVP you can apply for authorisation to use the “Notifications of major holdings (section 33 et seq. of the WpHG)” specialised procedure. Access to the procedure will be activated promptly once you have submitted your signed and scanned application form to BaFin. You can upload the application form directly within the MVP. Please apply for authorisation to use the specialised procedure in good time.
Note
It is possible to test the “Notifications of major holdings (section 33 et seq. of the WpHG). The submission of electronic voting rights notifications in the test procedure is not legally valid. For further information, see the web page on the specialised procedure TEST_Notifications of major holdings (section 33 et seq. of the WpHG).
Please address any technical questions on the electronic “Notifications of major holdings (section 33 et seq. of the WpHG)“ specialised procedure to: stimmrechte-support@bafin.de.
Please contact technical support if you have any technical questions or problems relating to the registration and use of the MVP Portal: mvp-support@bafin.de.
Note
Please note that electronic voting rights notifications can only be submitted once your access to the “Notifications of major holdings (section 33 et seq. of the WpHG)” specialised procedure has been activated. We will use the details you provide when registering for the MVP to inform you by e-mail when your access to the specialised procedure has been activated.
