PurposeThe purpose of this paper is to describe and compare the different ways in which the shareholder disclosure requirements under the European Union Transparency Directive have been implemented in the UK, France, and Germany. Belgium and Luxembourg have not yet implemented the Directive.Design/methodology/approachThe paper explains the categories of entities that must comply with reporting requirements, disclosure/reporting thresholds, categories of direct and indirect shareholdings to which these thresholds apply, and the reporting required methods of notification.FindingsThe paper finds that the new European rules broaden the categories of entities that must comply with the reporting requirements. In the UK, France and Germany, thresholds are calculated based on all shares or other financial instruments to which voting rights are attached and indirect holdings must be aggregated and separately identified. Additionally, Germany imposes further notification requirements with respect to options.Originality/valueThe paper provides a useful comparative analysis of new shareholder disclosure requirements in the UK, France, and Germany.

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