# BaFin Fines for Late Voting Rights Notifications > BaFin fined CM Center Management GmbH for two late voting rights notifications; the Local Court reduced the fines to €140,000. Source: https://www.mtrlegal.com/en/bafin-fines-late-voting-rights-notifications/ · Language: en · Updated: 2026-11-05 --- ## BaFin Fines for Late Voting Rights Notifications On 31 March 2026, the Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin, German Federal Financial Supervisory Authority) imposed fines totalling €200,000 on CM Center Management GmbH. According to BaFin, in September 2021 the company failed in two instances to submit voting rights notifications within the prescribed period, thereby breaching obligations under the Wertpapierhandelsgesetz (WpHG, German Securities Trading Act). The Amtsgericht Frankfurt am Main (Frankfurt am Main Local Court) reduced the total amount to €140,000 (AG Frankfurt am Main, judgment of 14 October 2026). BaFin published the corresponding notice on 5 November 2026. ### Current Status of the Proceedings and Context of the Information BaFin’s publication contains neither a case reference nor any information as to whether the decision of the Amtsgericht Frankfurt am Main is final and binding or whether an appeal has been lodged. The presumption of innocence applies until a final and binding decision has been rendered. The information concerning the infringements and the course of the proceedings is based on the [BaFin notice](https://www.bafin.de/SharedDocs/Veroeffentlichungen/DE/Massnahmen/40c_neu_124_WpHG/meldung_2026_11_05_cm_center_management_gmbh.html?cms_expanded=true). CM Center Management GmbH is registered in the commercial register of the Amtsgericht München (Munich Local Court) under HRB 115733 and has its registered office in Pullach i. Isartal. ## Notification Obligations Relating to Changes in Voting Rights ### Four Trading Days for the Voting Rights Notification Shareholders must notify the issuer and BaFin within four trading days if their voting rights reach thresholds stipulated by law. Under §§ 33 et seq. WpHG, a notification obligation also arises if such thresholds are exceeded or fallen below as a result of the acquisition or disposal of shares. According to BaFin’s account, the established infringement concerned the notification obligation under [§ 33(1), sentence 1 WpHG](https://www.gesetze-im-internet.de/wphg/__33.html). The authority stated that CM Center Management GmbH had failed to submit the required notifications on time in two instances in September 2021. ### Importance for Capital Market Transparency Voting rights notifications are intended to ensure the timely disclosure of material changes in shareholdings in listed companies. This provides market participants with information about ownership structures and potential positions of influence within a company. The disclosure obligations serve the following purposes in particular: - They create transparency regarding material changes in shareholdings. - They enable a better assessment of the ownership and control structures of listed companies. - They assist investors in making informed investment decisions. - They can help to identify potential corporate takeovers at an early stage. - They are intended to strengthen confidence in the proper functioning of the European equity market. ## Sanctions under the Wertpapierhandelsgesetz Anyone who fails to notify the issuer and BaFin in due time that relevant voting rights thresholds have been reached, exceeded or fallen below may be in breach of §§ 33 et seq. WpHG. BaFin is authorised to punish such an infringement by imposing a fine. For legal entities, the fine may amount to a maximum of €10 million or up to five per cent of total turnover. In the case of CM Center Management GmbH, the total amount initially imposed by BaFin was €200,000. The Amtsgericht Frankfurt am Main subsequently reduced it to €140,000. ## Further Capital Market Notification by the Company In relation to FCR Immobilien AG, CM Center Management GmbH appeared as a legal entity subject to notification requirements and closely associated with a person discharging managerial responsibilities. A directors’ dealings notification dated 22 August 2023 concerned the acquisition of shares from a non-cash capital increase in exchange for the contribution of dividend claims. In its notice concerning the fines, BaFin does not establish any connection between this transaction and the late voting rights notifications from September 2021, nor does it identify the issuer concerned. ## Advice on Capital Market Notification Obligations Voting rights notifications are subject to strict statutory deadlines and serve to disclose material shareholding structures in the capital market. Companies, investors and shareholders with questions regarding the scope of these obligations or regulatory proceedings can contact MTR Legal Rechtsanwälte. Further information is available under [Legal Advice on Capital Markets Law](https://www.mtrlegal.com/rechtsberatung/kapitalmarktrecht/).