ESMA’s implementing measures under the Transparency Directive should ensure shareholder transparency

This position paper comments on the level-2-implementing measures of ESMA under the revised Transparency Directive. The main issue is ESMA's interpretation of the exemptions from the major sharehholdings notificatons requirements. Deutsches Aktieninstitut generally calls for applying the exemptions rather narrowly since experience has shown that exemptions may also be used for secret stakebuilding.