15 July 2025 also delivered the wider context of the Financial Services Growth and Competitiveness Strategy, which is the government’s new vision for kickstarting growth in the financial services sector over the next ten years. There are many initiatives, for example progressing with the innovative PISCES (Private Intermittent Securities and Capital Exchange System) – a new type of stock exchange for companies who want to stay private for longer; encouraging a retail investment culture; and simplifying corporate reporting requirements, to name a few. The overall aim is to maintain and grow the UK as the world’s leading Financial Services hub, including by rebalancing to regulate for growth, cutting red tape for FinTech firms and driving forward initiatives.
Understanding that many of the initiatives are part of a wider context is helpful, and it is our industry’s role, to ensure that we work collaboratively with issuers, shareholders and other stakeholders to deliver these changes.
Some of the key initiatives we expect will require delivery by the end of 2027 include Step 1 of digitisation, the digitised share register; the changes required for the Register of Members to implement the requirements of the Economic Crime and Corporate Transparency Act (ECCTA); and accelerated settlement of trades to T+1. More immediately we are focussed on supporting the operational delivery of trading under the new PISCES. Each initiative involves a focus on collaboration, both externally and internally, to deliver the operational changes required and to effectively communicate with all interested and impacted stakeholders.
External stakeholder engagement has been a focus during this quarter, not only in relation to the digitisation of the UK shareholding framework, but also in relation to employee share plans. On the 11 September, together with ProShare, we were pleased to host a group of Parliamentarians to discuss the benefits of modernising the UK’s tax advantages SIP & SAYE share plans. This reform could support the government’s agenda to encourage a retail investment culture, through changes that could unlock ownership for hundreds of thousands of individuals.
Digitisation and dematerialisation
A government supported digitisation journey
The Final Report of the Digitisation Taskforce was released on 15 July 2025, in which it recommends a three-step process towards a fully intermediated securities chain: Step 1, the removal of paper share certificates and establishment of digitised registers; Step 2, preparing for a fully intermediated system; and Step 3, all shares transition into the intermediated securities chain.
The aims, as set out in the Final Report, fall under three headings: efficiencies for companies; empowerment for investors; and encouragement for retail investment.
Registrars are identified as key to delivery of Step 1 and as an industry we are preparing for our role on the Technical Group. EQ recognises and supports the ambitious timeline proposed for delivery of digitised registers by the end of 2027, which will require legislative changes, operational and technical development and an effective communications process to be put in place. At EQ we are continuing our digitisation journey with our product development and continue to encourage issuers to support their shareholders with the digitisation journey through the use of e-comms, removing cheques for dividend payments, and removing the need for a paper dividend confirmation/tax voucher, by utilising the CREST system to make dividend payments.
What’s next? HM Treasury has appointed the Chair of the Technical Group, Mark Austin, and the next step, as at the date of publication of this article, is the appointment of members to this Technical Group. This Group, which, as set out in the Final Report, will consider how to further develop and implement the recommendations and determine an implementation plan for Step 1, including an appropriate ‘go- live’ date.
Private company share trading
Preparing for the first trading under PISCES
PISCES, the Private Intermittent Securities and Capital Exchange System, is designed to bring together buyers and sellers of shares in private companies. Regulations and FCA rules are in operation, with the LSE now in receipt of its operator license and announcing its Private Securities Market. If you would like to learn more about PISCES, please access our webinar here.
What’s next? The expectation is for first auctions to take place at the end of 2025 or beginning of 2026. This will require focus and input from a range of stakeholders to achieve this. Registrars are actively involved in discussions with Euroclear on the operation of the trading and settlement of securities.
Transparency
ECCTA – implementation continues…
The Economic Crime and Corporate Transparency Act (ECCTA) continues to be implemented in the UK. We have developed an ECCTA hub to assist with keeping track of the changes that have been implemented and those that are to come.
With mandatory identify and verification (ID&V) now required from 18 November 2025, the work of company secretaries and the advisors that support them, is focussed on ensuring directors and Persons with Significant Control have completed their ID&V ahead of the first confirmation statements due after 18 November 2025.
From a share registration industry perspective, our focus is on the Register of Member changes required. As at the date of this article, there is no confirmed timeline for implementation of the changes, which as a reminder require a forename and surname for each registered member. We are working on industry standard communications that can be issued. Further information can be found in our article here.
What’s next? The CGI Registrars Group continue to seek clarification on the details of the changes for the Register of Members. We are waiting for secondary legislation to implement these changes with a definitive date to be set by the Department for Business and Trade (DBT).
Admission of securities to trading
Making it easier to raise capital on UK markets
On 15 July 2025, the FCA published a policy statement (PS25/9) on the public offers and admissions to trading regime which sets out feedback to CP24/12 and CP25/2, as well as the final FCA rules. The Public Offers and Admissions to Trading Regulations 2024 (POATRs) will replace the UK Prospectus Regulation. The POATRs regime is part of the wider reform of the UK capital markets that aim to make it easier to raise capital and to list in the UK.
Briefly, PS25/9:
- Raises the threshold at which a prospectus is required for further issuances to 75% of existing share capital (from 20%).
- Reduces the period that an IPO prospectus must be available to the public to three working days (from six).
- Indicates there will be further consultation around guidance for working capital statements and complex financial histories.
- Concludes voluntary prospectuses will only be available for admission to trading of securities that are exempt, but not those falling outside the scope of the PRM.
- Specifies the kind of statements that can be protected forward-looking statements using the three-part approach.
- Finalises a climate-related disclosure rule, clarifying this does not relate to investment entities. There will be a consultation on FCA guidance for issuers not in scope for this rule.
- Removes the listing application process on further issuances of securities in a class that is already listed.
What’s next? The final rules are expected to come into effect on 19 January 2026.
CREST transformation
The vision has six objectives:
- Increase the operational and financial resilience of Euroclear UK & International and the CREST system
- Increase the client value provided by the CREST system
- Enhance our business agility and support the UK financial markets
- Improve our operational efficiency and that of our clients
- Realise synergies with Euroclear group
- Remove the technology debt that has accrued in the current CREST system
The programme was set out to have fluidity built into the various stages of delivery to factor in the changing landscape; with initiatives such as T+1, PISCES and more recently the announcement of the Digitisation roadmap for the UK, the programme is well equipped to adapt. The focus has been on improving system resilience and speed of recovery in the event of failure, e.g. the removal of the requirements of the architecture linked to the Remote Legal Record solution. Customer focused changes include a replacement for the ‘client installed’ Graphical User Interface (GUI) used since the inception of CREST; EQ are in the final stages of Business Acceptance Testing the new WEBGUI+ solution which utilises standard browser features and API technology.
What’s next? Further work is planned in 2026 to modernise the connectivity network for all customers (EQ are signed up as an early adopter to stay close to these developments), paving the way for ISO standards messaging in the future. In parallel the development of ‘Mini-CREST’ is in the early stages of scoping; this will bring further operational resilience to the UK solution and is aimed squarely at a backup should the Single Settlement Engine (SSE) in Europe be subjected to a cyber-attack.
Accelerated Settlement T+1 (Settling a trade 1 day after execution)
UK and Europe, getting ready for October 2027
EQ have remained close to the Accelerated Settlement Taskforce (AST).
What’s next? At the latest industry forum much of the focus was on how to undertake Business Readiness testing and who should be involved; Euroclear UK & International (EUI) have reiterated that their test system is available on-demand and is fully equipped to support. The AST are looking to co-ordinate interested participants from the various sectors of the ‘pre-settlement’ industry. The custodian sub workstream is once again pushing for the adoption of EUI’s Dividends With Options (DWO) aka Electronic Election Entitlement (EEE) solution to standardise the UK with EU functionality; whilst this was identified as a potential in the final AST report, it was not seen as a mandatory requirement for ‘go live’.
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