PISCES: sandbox Regulations mark a new milestone

On 5 June 2025 The Financial Services and Markets Act 2023 (Private Intermittent Securities and Capital Exchange System Sandbox) Regulations 2025 (Regulations) came into force.

The Regulations establish the legal framework for the PISCES sandbox and authorise the Financial Conduct Authority (FCA) to make such rules as it considers “necessary or expedient” to implement and operate the PISCES sandbox. The Government has said that the FCA intend to publish their rules shortly after the Regulations come into force and in the meantime, the FCA has set up a webpage to support those looking to apply to run a platform within the sandbox.

This marks a key milestone in the development of PISCES and will be welcome news to potential PISCES companies and their shareholders who are keen to participate in trading events with the hope of generating liquidity.

Likewise, this is an important development for potential operators to whom the FCA has pledged their support by providing feedback on their suggested PISCES model, management and governance structure, target market and suite of governance documents (including the draft operating model and risk assessment), before they submit their formal applications. Further the FCA are offering a one-hour online meeting to allow potential operators to (a) give an overview of their business plan, operator rulebook and supporting documents, (b) ask questions about the PISCES regulatory framework and (c) provide a technical demonstration of their PISCES systems.

Following the publication of the FCA’s rules, they will provide further details about the process for applying to be a PISCES operator.

If you would like to discuss any of the points raised in this update, please contact AJ Venter (Partner, Corporate and M&A), Guy Francis (Director, Corporate and M&A) or Charlotte Hamilton (Senior Associate, Corporate and M&A).

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