Guide to Sensitive Industries

Sensitive Industries Overview

“Sensitive Industries” (SI) describes a part of shareholding disclosure regulation that requires additional disclosure thresholds in industries which have special significance. Each jurisdiction considers different industries to be “sensitive” and will decide on how closely they want to monitor private interests in those industries.

Typical Industries include:

  • Banking and Finance
  • Media
  • Gas/Electricity Utilities
  • Air Freight & Logistics
  • Airlines
  • Telecommunications
  • Insurance

Typical Thresholds:

There is no discernible pattern to SI thresholds, in some cases there is an absolute restriction on investment. See here for a list of lowest Sensitive Industries thresholds by jurisdiction.

Some jurisdictions will apply certain thresholds to foreign investors only (e.g. Japan).



Q. How does FundApps Sensitive Industries work?

A. FundApps sources Sensitive Industries thresholds from aosphere. These thresholds are represented in FundApps through SI Value Sets. There are three levels of SI Thresholds: 

  • Threshold Disclosure - after this threshold is crossed, disclosure is required.
  • Pre-Approval - before crossing this threshold, approval is required from the appropriate party in that jurisdiction.
  • Hard Stop - this threshold is a limit that cannot be crossed.

The Sensitive Industries rules then compare the industry of a given issuer against the thresholds contained in the SI Value Sets. 

Any results are flagged according to the relevant SI threshold.

Q. What information needs to be provided for FundApps Sensitive Industries?

A. For clients currently subscribed to the Shareholding Disclosure service, there is only one additional Property required for SI to run. 

This Property is "GICSIndustries" (i.e. the GICS code), which refers to the Global Industry Classification Standard. The GICS code defines which industry or industries an issuer operates in. The GICS code is a 6-digit code that is matched against the list of Industry Thresholds. 

If an issuer genuinely does not have a GICS Code, you can default to "XXXXXX" to prevent triggering Unknowns.

Q. Why is Commercial Services & Supplies included in the value set?

A. It is common that we include the GICS code for Commercial Services & Supplies, this is to cover the sub-industry Security & Alarm Services, which is often connected with restrictions on defence and security industries.

Q. How can I enable Sensitive Industries?

A. The SI rule package involves a subscription fee. If you have any questions about SI or are interested in a demo, please contact your CSM or contact

Q. Which jurisdictions are currently covered by Sensitive Industries?

A. You can find the latest list here.

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