London Stock Exchange approved as first PISCES operator

The launch of PISCES (Private Intermittent Securities and Capital Exchange System) earlier this year generated substantial interest across the private capital industry – the prospect of regulated venues for secondary share sales in mature, privately owned companies in the UK is unprecedented.  PISCES will offer certain private investors and shareholding employees with pre-exit liquidity and the opportunity to realise value prior to a sale or IPO. We here at Humphreys Law have been closely following the developments in PISCES.

While some stakeholders voiced concern that the PISCES model might be undermined by limited participation, those doubts are perhaps tempered for the time being by the news on 26 August 2025 that the London Stock Exchange (“LSE”) has officially been approved by the Financial Conduct Authority (“FCA”) as the first official PISCES operator.

The LSE will operate its very own Private Securities Market (“PSM”), through which it will organise, administer and support intermittent secondary share trading in late-stage private companies.  The LSE says that their PISCES platform will benefit from the LSE’s public markets infrastructure, technology and know-how.  And apparently the PSM will give these PISCES companies control as to the timing and frequency of share auction windows and those qualifying persons let into the process as sellers or buyers.

As a PISCES platform operator, the LSE will have some autonomy over the management of these secondary share sales (albeit the companies’ articles of association and the share transfer provisions within will apply or need to be amended to suit).  PISCES regulation will apply, including as regards the core disclosure regime and investor verification requirements.  See more on that here.

The PSM is expected to formally launch later on in 2025.  It will of course only operate within the confines of the PISCES sandbox – meaning its operation will act as a pilot for regulators to test and improve the wider PISCES framework – until 2030.

All PISCES operators, including the LSE, will be closely monitored by the FCA, although  given the regulator’s support and the LSE’s stature, collaboration between these organisations throughout the sandbox phase would not be surprising.

The FCA’s executive director of markets, Simon Walls, expressed support, stating that the LSE’s appointment as a PISCES operator marks “a major milestone in [their] drive to boost growth and unlock capital investment.”  Julia Hoggett, CEO at the LSE, also stated that the launch of their PSM “demonstrates [their] commitment to the creation of a genuine funding continuum from the private to public markets so that businesses in the UK and around the world can be effectively supported across all stages of their growth.”

Perhaps the LSE’s status as a PISCES operator will encourage other firms to join the regulatory sandbox as operators and companies to participate.  The FCA has published pre-application support and application support for those firms who may be interested in joining the LSE as a PISCES operator.

This Insight piece was written by Alina Merchant-Mohamed with input from Henry Humphreys.  Do please reach out to a member of the team if you have questions or queries relating to PISCES.

All the thoughts and commentary that HLaw publishes on this website, including those set out above, are subject to the terms and conditions of use of this website. None of the above constitutes legal advice and is not to be relied upon. Much of the above will no doubt fall out of date and conflict with future law and practice one day. None of the above should be relied upon. Always seek your own independent professional advice.

Humphreys Law