Guide to Sensitive Industries


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 interests in companies from 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 the 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 SI 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.

In some cases, depending on the jurisdiction where the value set is used, there are foreign-specific value set variants of the above types. (see, What are “Foreign” rules, below).

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 are “Foreign” rules? 

A. There are rules which only apply to investors who are domiciled in a country which is considered foreign to the jurisdiction with sensitive industries (i.e. excludes domestic investors). We have implemented a precondition in such rules to capture this. 

They are named to indicate so, for example, Sensitive Industries: Canada - Foreign - Hard Stop

They occur where the aosphere memo indicates certain thresholds only apply to foreign investors. 

There is a Domicile entity property to determine if the top entity is “foreign” in relation to Foreign rules. This should be populated with an ISO country code for the top entity where SI rules are run. 

If Domicile is not provided, the rules will conservatively deem the entity “foreign” for any foreign rules we create.

These rules otherwise operate according to the same structure as other SI rules (Threshold Disclosure, Pre-Approval, Hard Stop). 

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

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

This property is GICSSubIndustries (i.e. the GICS code), which refers to the Global Industry Classification Standard. The GICS code is an 8-digit code used to define the sub-industry or sub-industries an issuer operates. This code is matched against the list of industry thresholds. 

If a security’s issuer does not have a GICS Code, you may choose to default the input value to "XXXXXXXX" to prevent triggering Unknown alerts. However, this means that such positions will not be included in any Sensitive Industries rules.

Q. Can FundApps supply GICS codes? 

A. Yes! We are a redistributor of GICS codes directly from S&P and can integrate them directly into your files; please contact your account manager or FundApps Support.

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 FundApps Support.

Q. Which jurisdictions are covered by Sensitive Industries?

A. You can find the latest list here.

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