PISCES: new regulations published

On 15 May, the Government published the The Financial Services and Markets Act 2023 (Private Intermittent Securities and Capital Exchange System Sandbox) Regulations 2025 (SI 2025/583). 

Why are the regulations significant?

These regulations create the legal framework for PISCES. This is a key milestone for the creation of this new public / private cross-over market.  The regulations come into force on 5 June 2025.

What is PISCES? 

PISCES is a new regulatory regime which enables intermittent trading of private company shares.
PISCES platforms will be established by operators under this new regime.

PISCES and existing EMI and CSOP contracts

The government has now confirmed that it “will legislate in the next Finance Bill to allow employers, with their employee’s permission, to amend existing EMI and CSOP contracts to include a PISCES trading event as an exercisable event, without losing the tax advantages the schemes offer. This will allow employees with contracts amended in line with the legislation to exercise their options on PISCES and retain the tax advantages. The legislation will have retrospective effect, and in the interim HMRC will be able to use collection and management powers to not collect tax on exercise”. 

So this change should benefit the first PISCES trading events if those happen later this year.

What are the next steps?

The next steps are for:

• the FCA to publish the final PISCES sourcebook;
• PISCES operators to be authorised by the FCA;  and
• those authorized operators to publish their own rulebooks.

The rulebooks published by authorised PISCES operators will vary depending on the type of PISCES platform which each operator is launching and the intended market participants.

By the end of July 2025, the government has committed to legislate to allow existing EMI and CSOP contracts to be amended to include PISCES trading events whilst retaining existing tax advantages.

Further information

If you would like to discuss this update, please speak to your usual Burges Salmon contact, AJ Venter (Partner, Corporate and M&A), Nigel Watson (Partner, Incentives),  Nick Graves (Head of the Corporate Department) or Charlotte Hamilton (Senior Associate, Corporate and M&A). 

Further information can also be found on our PISCES web page.

Emma Reynolds, Economic Secretary to the Treasury, said: "Getting PISCES up and running will support UK growth companies. This will boost our capital markets and help to grow our economy, putting more money in working people’s pockets as part of our Plan for Change. We are also ensuring that employees will retain the tax advantages of shares traded on PISCES to boost the attractiveness of the product to high growth companies looking to expand."