In brief
- In a significant milestone for UK private markets, the first trades on PISCES platforms took place last week.
- The first PISCES transaction structures demonstrate the scope for a variety of PISCES use cases.
- We compare some of the notable differences between the two approved platform operators.
Background
The Private Intermittent Securities and Capital Exchange System (PISCES) is the regulatory framework governing a type of regulated trading platform that facilitates intermittent secondary trading in the shares of private companies. For an overview of the PISCES platforms and operators and links to our previous articles in this series, please refer to our December 2025 briefing: Understanding PISCES - who can invest and how?
Where are we now?
JP Jenkins and the London Stock Exchange (LSE) both obtained their authorisation from the FCA as PISCES operators in the second half of 2025 and last week carried out their first PISCES trades. This marks a significant milestone for the UK's private markets.
The first trades
On 24 February 2026, QPlay Ltd became the first company to trade on a PISCES platform upon its admission to JP Jenkins Private Market. QPlay is a UK-incorporated private limited company that produces "Outsmarted", a patented AI-powered quiz board game, and is held within the Velocity Capital Fund managed by Sapphire Capital Partners.
QPlay's first PISCES liquidity event opened a five-day order window on 18 March, during which eligible investors were able to place buy and sell orders for QPlay shares through financial intermediaries, including London brokers Peel Hunt and Winterflood Securities.
JP Jenkins' platform operates through a relatively straightforward structure. This structure does not necessitate any material reorganisation of the company's existing corporate arrangements.
- LSE: Oxford Science Enterprises and the Private Securities Market
The LSE has named its PISCES platform the Private Securities Market (PSM). PSM held its inaugural trading event on 25 March 2026, with shares in a Tradable Private Equity Investment Company (TPEIC) (a bespoke Luxembourg securitisation vehicle) being made available to eligible investors. The sole underlying asset of the TPEIC is a stake in Oxford Science Enterprises (OSE), a technology, artificial intelligence and life sciences investor with a valuation of approximately £1.3 billion.
OSE's portfolio encompasses more than 100 companies across deep tech, artificial intelligence, quantum computing, life sciences and health tech, all originating from Oxford's globally recognised research ecosystem.
The TPEIC is a novel structure designed specifically for the PISCES context. It holds an interest in OSE and issues freely transferable shares which are subsequently traded on PSM. Importantly, this means that OSE itself is not required to amend its constitution or share capital structure in order to meet PISCES's free transferability requirements. This is a potentially material consideration for any private company with a complex existing share structure. The Luxembourg vehicle additionally provides the capacity to ring-fence assets within that entity.
The fact that the LSE's first PISCES participant is accessed via a Luxembourg securitisation vehicle, rather than directly through a UK private company, is itself worthy of note. This highlights that using a PISCES platform is still in its infancy and that there is no universal solution when it comes to structuring for trading on a PISCES. The most appropriate approach for any given company will depend upon its existing corporate structure, share capital arrangements, shareholder composition and commercial objectives. Companies should seek careful advice before concluding that any particular model is suitable for their circumstances.
How the two platforms differ
Beyond the distinctions evident in the first transactions themselves, each operator has implemented the FCA's requirements in different ways.
On disclosure, for example:
- The LSE's PSM has adopted a Q&A process that goes beyond the core disclosure requirements prescribed by the FCA, allowing investors to put specific questions to companies in advance of a trading event.
- JP Jenkins requires companies to disclose all information that an investor could reasonably wish to know.
On trading mechanics, PSM auctions are limited to a single day, with companies having the ability to select between open auctions (accessible to all eligible investors) and permissioned auctions (where investors must apply and receive approval from the company through its Registered Auction Agent). On the JP Jenkins Private Market, there are options for "Intermittent Trading" (trading over a period of up to five consecutive business days each month) or a single monthly auction per month. Either type of trading event can be made subject to restrictions as to which investors can participate.
Both platforms' approaches remain consistent with the FCA's framework, which was always intended to afford operators the flexibility to build upon the baseline requirements in ways that suit their platforms and investor bases. However, the differences do mean that companies considering PISCES will need to assess which platform is best suited to their profile, and should be prepared for the differing obligations that each one imposes.
A broader trend
PISCES is a UK initiative, but its potential influence may extend beyond the UK's borders. The European Commission has been consulting on proposals that share a number of conceptual similarities with PISCES. It remains too early to assess how those proposals will evolve, but the UK's experience with PISCES may prove informative for other jurisdictions.
Closer to home, we are aware that a significant number of companies are actively considering joining a PISCES platform. Whether that momentum is sustained will depend, in part, on the experience of these early movers and on how companies and their advisers approach PISCES.
How can we help?
Our Corporate team has been engaged in the development of the PISCES framework since its inception. If you are a company considering participating on a PISCES platform or would like to know more about the framework generally, please contact Arthur Horsfall or Nicholas McVeigh who would be happy to discuss further.