Specific situations
Specific situations

[Last updated: 1 January 2024, unless otherwise noted]

Large companies. There are no additional requirements, or any changes in the normal requirements, that apply to very large multinational companies.

Industries. Additional disclosures are required for specialist issuers (such as property, mineral, scientific research-based companies). Issuers that are involved only in exploration of mineral resources and are not undertaking or propose to undertake their extraction as a business activity would not be classed as mineral companies.

  • Furthermore, once listed on Euronext Amsterdam, shareholders of the listed company have the following ongoing disclosure obligations:
    • As soon as the substantial holding or short position equals or exceeds 3% of the issued capital, the holder should report this to the AFM. Subsequently, the holder should notify the AFM again when his substantial holding or short position consequently reaches, exceeds or falls below the following threshold: 3%, 5%, 10%, 15%, 20%, 25%, 30%, 40%, 50%, 60%, 75% and 95%. Such disclosure will be published in the AFM's online register.
    • Shareholders must disclose any position attaining 0.2% of the issued share capital, and of every subsequent 0.1% above this threshold (significant net short positions in shares as required under the regulation on short selling (Regulation (EU) No 236/2012) and certain aspects of credit default swaps). Notifications starting at 0.5% and every subsequent 0.1% above this threshold will be made public via the short selling register. Disclosures must also be made of net short positions in sovereign debts that exceed or fall below specific threshold values, but these notifications will not be made public.

Diversity requirements. On 1 January 2022 new legislation on diversity has entered into force in the Netherlands. The legislation consists of two measures, being:

  • A mandatory quota of at least one-third women and at least one-third men for supervisory directors or non-executive directors of Dutch companies listed on a regulated market in the Netherlands, e.g., Euronext Amsterdam.
  •  Appropriate and ambitious targets, in the form of a target figure, for the ratio of men to women on the management board or executive directors and the supervisory board or the non-executives (if the abovementioned mandatory quota does not apply) and among categories of employees in managerial positions, to be determined by large public companies.