Who must disclose a short position?
Every market on this site publishes short-selling data, and no two of them mean quite the same thing by it. The differences are not cosmetic: the same fund, holding the same size of position, can be named in public in Paris, counted anonymously in London, and reported in Sydney at a fraction of the size. This page sets the rules side by side so a number from one market is not read as though it came from another.
The two thresholds that matter
Almost every disclosure regime has two separate trigger levels, and confusing them is the most common mistake made with this data:
- A private notification threshold: the level at which a position holder must tell the regulator. Nothing is published. The regulator knows; the public does not.
- A public disclosure threshold: the level at which the position, or an aggregate containing it, reaches a published file.
A position sitting between the two is real, known to the regulator, and completely invisible to you. That gap is the single biggest reason published short interest understates the true figure.
The rules, market by market
United Kingdom (FCA)
A net short position must be notified privately to the FCA once it reaches 0.2% of a company's issued share capital, and again at every 0.1% step up or down. Notification is due by 15:30 the next working day. Publication is aggregate and anonymous: the FCA sums every notified position of 0.2% or more and publishes one figure per company per working day. No holder is ever named. Scope is set by the Reportable Shares List; a share that is not on it carries no UK disclosure obligation at all. Full detail in the ANSP explained.
Europe (national regulators, EU Short Selling Regulation)
The private notification threshold is 0.1% of issued share capital, reported to the national regulator. At 0.5% the position becomes public and named: the register shows the holder's name, the company, the exact percentage and the position date, updating at every 0.1% step until the position falls back below 0.5%, an exit that is itself disclosed. Each country runs its own register; there is no single EU-wide file. Europe is now the only major region that still names individual short sellers, which is why our position holder pages exist at all. See Europe's named short registers.
Australia (ASIC)
Australia sets the lowest bar by a wide margin. A short position must be reported to ASIC if it is worth at least A$100,000 or 0.01% of the product's issued capital, whichever is reached first, and reporting happens every day, not only at threshold crossings. ASIC aggregates the reports per product and publishes daily. Holders are not named. Because the reporting floor is so low, the Australian figure is best read as a near-complete census of open short positions rather than the floor that the UK and European numbers represent. See Australia's short position data.
United States (FINRA)
The US model is different in kind: investors have no public short-disclosure obligation at all. Instead, FINRA Rule 4560 requires member broker-dealers to report the short positions on their books as of two settlement dates a month, and FINRA publishes one consolidated total per security about nine business days later. The figure is close to a census of settled short interest, but it is aggregate and anonymous by construction: there is no threshold below which a position escapes it and no register on which a holder could be named. See US short interest explained.
Side by side
| Market | Private notification | Public disclosure | Holders named? |
|---|---|---|---|
| UK (FCA) | 0.2% of issued share capital | Aggregated from 0.2% | No |
| Europe (national regulators) | 0.1% of issued share capital | 0.5%, per position | Yes |
| Australia (ASIC) | A$100,000 or 0.01%, reported daily and published in aggregate | No | |
| US (FINRA) | No investor disclosure; broker-dealers report firm positions twice a month, published in aggregate | No | |
What this means when you compare markets
Because the floors differ by a factor of twenty between Australia and the UK, and by more again against Europe's public threshold, the same underlying level of shorting produces very different published percentages. An Australian company showing 5% and a UK company showing 5% are not measured the same way: the Australian figure captures almost everything, while the UK figure counts only positions of 0.2% or more and omits the rest entirely.
The practical consequence is that cross-market league comparisons are the least reliable thing you can do with this data. Comparing a company against its own history, within one market and one set of rules, is the comparison the data actually supports, which is why every company page here leads with a time series rather than a cross-border ranking.
Who the rules apply to
Disclosure obligations attach to the position holder, the entity whose net short position crosses the threshold, not to the broker executing the trade or the venue it trades on. Positions are measured net: long exposures in the same issuer offset short ones, which is why the published figure is a net short position rather than a count of shares borrowed. How that netting works, and what it hides, is covered in what is short interest.
This page is educational and describes public disclosure rules as we understand them from regulators' published material. It is not legal or compliance advice, and nothing on this site is investment advice. If you have a reporting obligation, work from the regulator's own rules.