Yes, it is possible to make an offer of securities to the public in more than one Member State using this exemption using the lowest threshold of the individual Member States in which the offer is made.

The issuer should determine the lowest threshold for a prospectus by checking the thresholds set in the relevant individual Member States. ESMA has published a document containing the thresholds which are set by the Member States. However, issuers should familiarise themselves with the requirements in each Member State where the offer is made, because some Member States may have additional requirements such as the publication of documentation or the registration of the offering.