SSR 2 Position reporting 

1. (1) whether that person is domiciled or established within the United Kingdom or in a third country; and
2. (2) regardless of:
   1. (a) where the short selling activity takes place; and 

   2. (b) whether the short selling activity takes place on or outside a trading venue.

       

1. (1) the FCA has disapplied these rules in respect of that admitted share in accordance with SSR 4; or

2. (2) the market maker exemption or stabilisation exemption under SSR 5 applies to market making activities carried out by a person in respect of that admitted share.

    

1. (1) SSR 2.3 to SSR 2.6 provide rules and guidance regarding when a notification may be required and practical matters regarding notifications.
2. (2) SSR 2.7 provides rules and guidance regarding the timing for submission of a notification.
3. (3) SSR 2.8 to SSR 2.10 provide rules and guidance regarding the method for calculating a net short position.
4. (4) SSR 2.11 provides rules and guidance regarding the calculation of issued share capital for the purposes of calculating net short positions.
5. (5) SSR 2.12 to SSR 2.14 provide rules and guidance regarding what constitutes a short position and long position.
6. (6) SSR 2.15 to SSR 2.16 provide rules and guidance regarding the calculation and notification of net short positions by persons undertaking management activity, and in groups.
7. (7) SSR 2.17 provides rules and guidance regarding the calculation and notification of net short positions held through ETFs, baskets and indices.
8. (8) SSR 2.18 provides rules and guidance regarding using a delta-adjusted methodology for calculating net short positions.
9. (9) SSR 2.19 provides rules and guidance regarding record retention and position verification.

1. (1) their net short position has reached or exceeded 0.2% of the issued share capital of a company with admitted shares;
2. (2) their net short position has fallen below 0.2% of the issued share capital of a company with admitted shares; or

3. (3) having reached or exceeded 0.2%, their net short position has reached, exceeded or fallen below an additional 0.1% increment.

    

1. (1) persons carrying on management activity, as provided for in SSR 2.15; and

2. (2) persons in a group and persons reporting on behalf of a group, as provided for in SSR 2.16.

    

1. (1) For the purposes of SSR 2.3.1R a notification of a person’s net short position may be made by a third party, including an investment firm acting on behalf of its clients. 

2. (2) Where (1) above applies, the person holding the net short position remains responsible for compliance with the rules in SSR 2. 

    

1. (1) if a person has previously notified a net short position under SSR 2.3.1R, that person is not required to submit any additional notifications under SSR 2 from the date on which the admitted share is removed from the reportable shares list; and

2. (2) if a person is required under SSR 2.3.1R to notify a net short position but, the next working day, the admitted shares to which the notification relates are removed from the reportable shares list, the person would not be required to submit the notification.

    

1. (1) a person would need to notify the FCA when their net short position reaches, exceeds or falls below a successive multiple of 0.1% above the base notification threshold, for example 0.3%, 0.4%, 0.5% or 0.6%; 

2. (2) a change from 0.31% to 0.39% would not require notification as it does not reach, exceed or fall below a 0.1% increment, but a change from 0.39% to 0.41% would require notification, as the net short position exceeds an additional 0.1% increment.

    

1. (1) In accordance with regulation 13(1) of the Short Selling Regulations 2025, the FCA may require net short positions to be notified at a different threshold to that specified in SSR 2.3.1R(1), for example, 0.1%.
2. (2) The FCA’s statement of policy provides further information on the use of the power in regulation 13(1) of the Short Selling Regulations 2025.

1. (1) When a person is making a notification under SSR 2.3.1R for the first time, the notification must contain all the information specified in both SSR 2 Annex 1R and SSR 2 Annex 2R.
2. (2) In all other cases, the information in SSR 2 Annex 2R must be provided.
3. (3) The requirement in (1), with respect to the information in SSR 2 Annex 1R, does not apply to a person who has already provided the information in SSR 2 Annex 1R before 13 July 2026, under:
   1. (a) Article 5 of the UK version of Regulation (EU) No 236/2012 of the European Parliament and of the Council of 14 March 2012 on short selling and certain aspects of credit default swaps, which was part of UK law by virtue of the EUWA; or

   2. (b) Article 5 of Regulation (EU) No 236/2012 of the European Parliament and of the Council of 14 March 2012 on short selling and certain aspects of credit default swaps.

       

1. (1) SSR 2 Annex 3R should be used when information about the net short position in an admitted share is wrong – for example, the true position is 0.3%, but the position notified is erroneously 0.4%; and
2. (2) SSR 2 Annex 4R should be used when information about the admitted share is wrong – for example, the notification lists the wrong company’s name.

1. (1) A person has a net short position in the issued share capital of a company with admitted shares if the person’s total short position in the issued share capital of that company exceeds the person’s total long position in the issued share capital of that company.
2. (2) A short position in the issued share capital of a company is the position resulting from:
   1. (a) a short sale of a share issued by the company; or
   2. (b) entering into a transaction, other than a short sale of a share issued by the company, where an effect of the transaction is to confer a financial advantage on the person entering into that transaction in the event of a decrease in the price or value of a share issued by the company.
3. (3) A long position in the issued share capital of a company is the position resulting from:
   1. (a) holding a share issued by the company; or

   2. (b) entering into any transaction where an effect of the transaction is to confer a financial advantage on the person entering into that transaction in the event of an increase in the price or value of a share issued by the company.

       

1. (1) all transactions that occurred since the last working day, irrespective of whether the transactions have taken place during normal trading hours; and

2. (2) any change in the issued share capital of the company concerned.

    

1. (1) When making a notification of a net short position under this chapter, a person must express their net short position as a percentage of the relevant company’s issued share capital.

2. (2) The net short position expressed as a percentage of the company’s issued share capital must be calculated by dividing the net short position in equivalent shares by the total issued share capital of the company and multiplying this figure by 100.

    

1. (1) if the net short position is 0.3199 %, the notification should provide a position of 0.31%; or

2. (2) if the net short position is 0.1999%, this would truncate to 0.19%, hence no notification would be required.

    

1. (1) For the purpose of calculating a net short position, both the numerator (the net short position in equivalent shares) and the denominator (the total issued share capital) should include all classes of issued shares, irrespective of their characteristics (common stock, preferred, treasury shares etc) and irrespective of any voting rights attached.

2. (2) Where a company has several share classes, the total number of shares issued in each class should be taken into account and added together to calculate the company’s total issued share capital and a person’s net short position in equivalent shares. 

    

1. (1) Changes to the issued share capital of a company with admitted shares may change a person’s net short position and trigger notification obligations under SSR 2.3.1R.
2. (2) For example:
   1. (a) an increase in the issued share capital of a company could lead to a decrease of a person’s net short position (as expressed in accordance with SSR 2.10.1R) in that company, all other things being equal; or

   2. (b) a decrease in the issued share capital of a company could lead to an increase of a person’s net short position (as expressed in accordance with SSR 2.10.1R) in that company, all other things being equal.

       

1. (1) In determining the issued share capital of a company for the purpose of calculating a net short position, a person should act reasonably having regard to publicly available information about the issued share capital.

2. (2) For the purposes of (1), ‘publicly available information’ refers to information which is readily accessible free of charge.

    

1. (1) For the purposes of SSR 2.11.5G, a person may use information from various sources, including:
   1. (a) the total number of voting rights and capital disclosed by companies under DTR 5.6.1R or DTR 5.6.1AR;
   2. (b) filings at Companies House (such as SH01 and SH06 filings); and
   3. (c) information provided by commercial or market data providers.

2. (2) Where a person relies on the total number of voting rights and capital disclosed by a company under DTR 5.6.1R or DTR 5.6.1AR, the person should only use that figure where a person acting reasonably considers that the total number of voting rights and capital published under DTR 5.6.1R or DTR 5.6.1AR is a fair and reasonable representation of all of the company’s issued share capital. Where this is not the case, the person should only use the figure disclosed under DTR 5.6.1R or DTR 5.6.1AR as a source to determine the issued share capital, and not as an equivalent substitute for the issued share capital itself.

    

1. (1) a sale by either party under a repurchase agreement where one party has agreed to sell the other a security at a specified price with a commitment from the other party to sell the security back at a later date at another specified price;
2. (2) a transfer of securities under a securities lending agreement;
3. (3) entry into a futures contract or other derivative contract where it is agreed to sell securities at a specified price at a future date;
4. (4) the sale of financial instruments that have been transferred under a stock lending or repurchase agreement, provided either that the securities will be returned or that the transferor recalls the securities so that settlement can be effected when it is due;
5. (5) the sale of a financial instrument by a person who has purchased the financial instrument prior to the sale but has not taken delivery of that financial instrument at the time of the sale, provided that the financial instrument will be delivered at such time that settlement may be effected when due; or

6. (6) the sale of a financial instrument by a person who has exercised an option or a similar claim on that financial instrument, provided that the financial instrument will be delivered at such a time that settlement may be effected when due.

    

1. (1) the person owns the share in accordance with SSR 2.12.2R; or 

2. (2) the person has an enforceable claim to be transferred ownership of the share in accordance with the law applicable to the relevant transaction, including where the share is held by a nominee. 

    

1. (1) Shares received as a consequence of a bonus share issue or share dividend distribution must be taken into account as long positions when calculating a net short position.

2. (2) Shares received as a consequence of a share dividend distribution that a borrower is obligated to return to a lender under the terms of a stock lending agreement must not be included by the borrower when calculating their net short position. 

    

1. (1) options;
2. (2) covered warrants;
3. (3) futures;
4. (4) index-related instruments;
5. (5) contracts for differences;
6. (6) shares or units of ETFs;
7. (7) swaps;
8. (8) spread bets;
9. (9) packaged retail or professional investment products;
10. (10) complex derivatives;
11. (11) certificates linked to shares;
12. (12) global depositary receipts; and

13. (13) American depositary receipts.

     

1. (1) where a convertible bond converts into shares that are not yet issued, these must not be included in the long positions when calculating a net short position;
2. (2) where a convertible bond converts into shares which have been issued, these must be included in the long positions when calculating a net short position; and

3. (3) if a person does not know whether the convertible bond converts into shares which have been issued, the convertible bond must not be included in the long position when calculating a net short position. 

    

1. (1) short selling activity undertaken as part of its management activity; and

2. (2) short selling activity which is not undertaken as part of its management activity.

    

1. (1) include positions of the funds and portfolios the management of which has been delegated to it by a third party;
2. (2) exclude positions of the funds and portfolios the management of which it has delegated to a third party;
3. (3) calculate the net short position in a company for each individual fund and portfolio that it has under management, irrespective of legal form;
4. (4) include both cash positions and positions held by the individual fund through financial instruments referred to in SSR 2.14.1R; and 

5. (5) aggregate, for each company, only the net short positions held by its funds and/or portfolios.

    

1. (1) In the case of umbrella structures, the calculation of the net short position must take place at the level of the respective sub-funds.

2. (2) In the case of master-feeder structures, the calculation of the net short position must take place at the level of the respective master fund.

    

1. (1) The aggregation referred to in SSR 2.15.2R(5) should take into account positions held at the level of entity, division, unit or department that manages the fund or portfolio. 

2. (2) As only funds or portfolios with net short positions are to be aggregated in calculating the total net short position across a management entity’s management activity, the management entity should not take into account funds or portfolios with net long positions in a company.

    

1. (1) the short selling activity giving rise to the net short position is not management activity;
2. (2) the person is a member of a group; and

3. (3) the group’s aggregate net short position, calculated in accordance with SSR 2.16.7R, has reached or exceeded 0.2% of the issued share capital of that company. 

    

1. (1) Subject to (2), the ultimate parent undertaking of a group which carries on short selling activity must notify the FCA of the group’s net short position in the issued share capital of a company, calculated in accordance with SSR 2.16.7R, when any of the circumstances in SSR 2.3.1R apply to the group’s aggregate net short position in that company.
2. (2) Where a group has designated a different member of the group to notify the FCA for the purposes of (1), this rule applies to that person instead of the ultimate parent undertaking.
3. (3) SSR 2.4 to SSR 2.14 and SSR 2.17 to SSR 2.19 apply to notifications required by (1) as they apply to notifications required by SSR 2.3.1R.

4. (4) For the purposes of the information specified in SSR 2 Annex 2R, the person notifying under (1) or (2) must specify under ‘Group Notification Status’ that the ‘position is reported on behalf of a group’.

    

1. (1) A person must notify the FCA of their net short position in the issued share capital of a company when the following circumstances apply:
   1. (a) the person has previously notified the FCA of a net short position in the issued share capital of a company that had reached or exceeded 0.2% under SSR 2.3.1R(1);
   2. (b) the person has not since notified the FCA that their net short position in the issued share capital of the company has fallen below 0.2% under SSR 2.3.1R(2); and
   3. (c) a group-level notification is made under SSR 2.16.2R that their group’s net short position in the issued share capital of that company has reached or exceeded 0.2%.
2. (2) A person must notify under (1) on the same day as the notification referred to in (1)(c).
3. (3) When notifying under (1), the notification must contain the information specified in SSR 2 Annex 2R and must in particular specify:
   1. (a) the position date as the same position date as that specified in the notification made on behalf of the group under (1)(c); and
   2. (b) that the position reporting exemption applies because group-level position reporting is in effect.
4. (4) Other than as specified in (2) and (3), SSR 2.4 to SSR 2.14 and SSR 2.17 to SSR 2.19 apply to a notification under SSR 2.16.1R as they apply to a notification under SSR 2.3.1R.

1. (1) SSR 2.16.2R applies irrespective of whether any net short positions in the issued share capital of the company held by individual members of the group would, but for SSR 2.16.1R, be individually notifiable.
2. (2) The purpose of the notification in SSR 2.16.3R is to enable the FCA to identify persons who:
   1. (a) had previously notified the FCA of a net short position in the issued share capital of a company at or above 0.2% that remains open; and
   2. (b) will cease making additional notifications in respect of their open position in that company because their position has become subsumed by a net short position in that company at or above 0.2% calculated at group level in accordance with SSR 2.16.1R.
3. (3) As per SSR 2.16.3R(2), such a person must notify this to the FCA on the same day as the group-level notification in relation to the group-level position is made under SSR 2.16.2R.   
4. (4) If, following the circumstances in (2), the group-level position then falls below 0.2% but that person’s position remains at or above that threshold, that person must further notify this to the FCA under SSR 2.16.5R and revert to reporting their individual position to the FCA under SSR 2.3.1R.
5. (5) Unless SSR 2.16.3R applies, where a person’s net short position meets or exceeds 0.2% of the issued share capital of a company on the same day as their group’s net short position meets or exceeds 0.2% of the issued share capital of that company, only a group-level position must be notified because:
   1. (a) with respect to a person’s individual notification requirement under SSR 2.3.1R, the conditions in SSR 2.16.1R are met; and
   2. (b) a notification on behalf of the group needs to be made because the circumstances in SSR 2.16.2R apply to the group-level position.
6. (6) Even if a person is not required to notify under SSR 2.16.1R, it will still be necessary for them to calculate net short positions on an ongoing basis given the group-level position may fall below 0.2% of the issued share capital of the company concerned.

1. (1) on the same day as the day on which a notification is made on behalf of the group under SSR 2.16.2R that the circumstances in SSR 2.3.1R(2) apply to the group’s net short position; and

2. (2) for the purposes of SSR 2 Annex 2R, specifying the position date as the same position date as that specified in the notification made on behalf of the group under SSR 2.16.2R.

    

Where the person to whom SSR 2.16.5R applies is also the person responsible for reporting at a group level under SSR 2.16.2R, they will accordingly need to make 2 notifications on the same day:

1. (1)  a notification under SSR 2.16.2R in respect of the group-level position falling below 0.2%; and
2. (2)  a notification under SSR 2.3.1R and SSR 2.16.5R in respect of their individual position being at or above 0.2%.

1. (1) each person within a group calculates their individual short position and long position in the issued share capital of the company in accordance with SSR 2, excluding their positions held by virtue of carrying on management activity; and

2. (2) the individual short positions and long positions are then aggregated and netted to arrive at the group net short position. 

    

1. (1) Subject to SSR 2.17.4R, any transaction that confers a financial advantage in the event of a change in the price or value of an admitted share held as part of a basket, index or ETF must be included when calculating the position in the admitted share.
2. (2) Positions in these financial instruments must be calculated taking into account the weight of that share in the underlying basket, index or ETF.

1. (1) The person is not required to obtain real-time information on the composition or weightings of an index, basket of securities or ETF, to the extent that it is not readily accessible free of charge. 

2. (2) Persons should instead use the most recent publicly available information for look-through purposes. Such information, notably on indices, is generally available free of charge when provided with a certain delay.

    

1. (1) In accordance with SSR 2.8.2R, a person must account for any position in a financial instrument on a delta-adjusted basis when calculating their net short position.
2. (2) To calculate a net short position including equity or cash investments and derivatives, a person must calculate the individual delta-adjusted position of every derivative that is held in the portfolio, adding or subtracting all cash positions as appropriate.
3. (3) For the purpose of (1):
   1. (a) any cash positions must have a delta of 1;
   2. (b) to calculate the delta of a derivative, the person must take into account the current implied volatility of the derivative and the closing price or last price of the underlying instrument; and
   3. (c) the person must calculate net short positions by netting long and short delta-adjusted positions in a given company.
4. (4) A person must ensure that the same methods are used for calculating both long positions and short positions in relation to the same shares.
5. (5) A nominal cash short position must not be offset by an equivalent nominal long position taken in derivatives.
6. (6) A delta-adjusted long position in derivatives may not compensate an identical nominal short position taken in other financial instruments due to the delta adjustment.
7. (7) A person that enters into derivatives contracts giving rise to net short positions that must be notified in accordance with SSR 2.3.1R must calculate changes to a net short position in their portfolio arising from changes in the delta.