Choosing the Right PISCES Platform for Private Company Liquidity

As of 21 April 2026, the UK now has three distinct routes to regulated secondary trading in private company shares, and the design choices each platform has made tell you a lot about who they are built for.

The FCA's PISCES sandbox, the rules for which were finalised in June 2025 and which runs until 2030, created a regulated framework to address one of the long-standing structural gaps in the UK private capital markets: how shareholders in private companies can access liquidity without a full public listing or a cumbersome bilateral transfer. Three platforms have now been approved to operate within that framework: the London Stock Exchange's Private Securities Market (PSM), JP Jenkins' Private Market, and most recently, on 21 April 2026, Asset Match. The LSE and JP Jenkins both completed their first trading events in March 2026; Asset Match, having only been recently approved as a PISCES operator, has not yet held its first PISCES event.

While all three operate under the same FCA sandbox rules, including restrictions to secondary-only trading, prescribed core disclosure requirements, and exemptions from stamp duty and SDRT, each platform has adopted a distinct operating model. For companies, shareholders, and their advisers, understanding those differences is not academic. It is central to making the right platform choice.

A shared framework, three different philosophies

The LSE's PSM is designed to resemble a traditional exchange environment, adapted for private companies. Operated by a recognised investment exchange, it requires companies to meet quantitative financial thresholds: at least two of a £10m fundraise with experienced independent investors, £20m in audited total assets, or £10m in audited annual turnover. These criteria serve as proxies for prior external scrutiny and are designed to ensure that admitted companies have established track records. It is no coincidence that the PSM's first auction, held on 25 March 2026, involved Oxford Science Enterprises, a venture portfolio valued at £1.3bn, facilitated through an innovative structure specifically designed for the platform.

JP Jenkins has taken a deliberately different approach. It imposes no financial thresholds, requiring instead structural governance standards: a shareholder resolution, a minimum of two directors and five shareholders, and constitutional documents that permit free transferability. This opens the platform to a broader universe of private companies, including earlier-stage and venture-backed businesses. JP Jenkins pairs its lighter admission criteria with a"Sweeper Model", an affirmative obligation on directors to disclose, at each trading event, any information a reasonable investor would expect to receive. Its first PISCES event, a five-day trading window for QPlay (the company behind the Outsmarted digital board game), completed on 24 March 2026, demonstrating the platform's accessibility to companies well below the LSE's eligibility thresholds.

Asset Match is the most recent entrant to the PISCES arena. Its PISCES Rulebook imposes no quantitative financial thresholds, requiring only that a company is incorporated under the Companies Act 2006 (or is an overseas company), is not admitted to trading on any other trading venue, and can demonstrate adequate processes for meeting disclosure requirements. Asset Match’s auction-only model aligns more closely with the LSE's approach than JP Jenkins's "intermittent trading windows", but its lighter eligibility criteria and established track record position it as a credible middle ground between the two. All three platforms accommodate overseas companies, with Asset Match being the most explicit in its published Rulebook.

Trading formats and transparency

The platforms also diverge in how and when trading occurs. The LSE PSM operates through discrete, single-day auctions, concentrating liquidity at a single clearing point in a format suited to controlled execution and confidentiality, particularly for larger institutional block trades.

JP Jenkins offers greater flexibility: in addition to periodic auctions, companies can opt for "intermittent trading windows" of up to five consecutive business days per month, with real-time indicative pricing visible to all intermediaries and post-trade results published as close to real-time as technically possible. This model supports ongoing price discovery and incremental liquidity, though it may increase information sensitivity for companies with concentrated share registers.

Asset Match operates periodic auctions only, but with a distinctive structured multi-phase process: a “Closed Period” of at least five business days (during which disclosures are published and no orders are accepted), followed by a “Designated Auction Period” in which investors can place and amend orders while viewing a near real-time running order book showing buy and sell depth at each price level and an estimated “Trading Price”. This level of pre-trade transparency during the order placement phase is the most granular of the three platforms, and is designed to support informed price discovery before orders are matched at the auction point.

Settlement infrastructure also differs materially between the platforms. Both the LSE and JP Jenkins settle transactions via CREST on a T+2 basis, giving investors the same post-trade certainty and electronic settlement infrastructure used in public markets. Asset Match's published Rulebook takes a different approach: transactions are effected on a bilateral basis between Members, and Asset Match is expressly not a party to, nor responsible for, settlement. Members are required to have their own adequate clearing and settlement arrangements in place. The Rulebook does not prescribe CREST or any specific settlement mechanism, though it is possible that the unpublished PISCES Company Handbook or individual Member Agreements address this in practice. Settlement via CREST therefore remains an option on the Asset Match platform, although Asset Match will not be a party to these arrangements. For companies and investors accustomed to the certainty of centralised electronic settlement, this is a practical distinction worth understanding before selecting a platform.

The platforms also differ in their approach to volatility controls: JP Jenkins applies automated circuit breakers where the indicative execution price deviates by more than 5% from the previous closing price, the LSE operates Price Monitoring Extensions through its established trading parameters, and Asset Match relies on discretionary powers to refuse erroneous orders and to postpone, suspend or cancel dealing where it considers this in the best interests of the platform's operation.

Intermediaries, disclosure and fees

All three platforms rely on FCA authorised intermediaries, but through different structures. The LSE requires brokers to register as Registered Auction Agents (RAAs), a new LSE member category that controls investor eligibility verification and disclosure portal access. JP Jenkins works through a broader network of over 60 brokers and wealth managers integrated into its systems, enabling wider distribution and faster onboarding. Asset Match operates through Approved Intermediaries who must be authorised or registered by the FCA, with each intermediary subject to Asset Match's own approval process.

On disclosure, the approaches are notably different. The LSE provides a centralised portal with an investor Q&A facility but does not mandate disclosure beyond the FCA's prescribed core requirements. JP Jenkins' Sweeper Model goes further, placing the onus squarely on directors to disclose proactively, a notable feature of its more accessible admission framework. Asset Match takes a more interventionist monitoring role: it conducts risk-based monitoring with a basic completeness check of company disclosures and designates six categories of Core Disclosure that may never be omitted from a trading event (noting that this goes beyond the FCA's baseline requirements as the FCA Sourcebook permits omission of all core disclosure items in exceptional circumstances, except directors' transactions, which may never be omitted).

One area where the platforms' published rules diverge from the FCA's baseline in an unexpected direction concerns price parameters. The FCA Sourcebook requires all operators to mandate six specific disclosures where a company sets floor or ceiling prices for its shares, including whether the company prepared the valuation or price parameters with the agreement of another person, such as a key investor, and the identity of any such person or independent third party. The LSE's Core Disclosure form at CD 13 replicates the FCA's six-limb test in full. However, neither JP Jenkins's nor Asset Match's published rules appear to expressly include the requirement to disclose whether price parameters were agreed with another person. It is possible that this is addressed through unpublished supplementary documents or through operational practice, but on the face of the published rules, the LSE is the only platform whose price parameter disclosure requirements fully mirror the FCA's prescribed minimum. Given the significant discretion that companies have in setting price parameters, and the FCA's express concern that valuations are often agreed with key investors rather than prepared independently, this is a point that advisers may wish to explore with each platform directly.

Fee structures reflect these differing philosophies. The LSE publishes standardised platform fees: £25,000 per annum (including two auctions), with introductory waivers to encourage early adoption. Both company fees and additional auction participation fees are waived in full until 31 December 2026. For intermediaries, the phased fee structure is particularly notable: no transaction fees are payable by either buyers or sellers until 30 June 2026; from 1 July 2026, only the seller pays a 1% transaction fee while buyers remain exempt; and full fees of 1% for sellers and 0.75% for buyers take effect from 1 July 2027. New member firms that only facilitate access as RAAs also benefit from a waiver of annual membership fees until 31 December 2027. The practical effect is that during the initial period of the PSM's operation, the cost of transacting on the platform is substantially reduced, a deliberate strategy to build critical mass in the platform's early stages. JP Jenkins' fees are agreed on a bespoke basis through individual service agreements, offering flexibility but reducing direct comparability. Asset Match's PISCES fee schedule is not yet publicly available.

Which platform is right?

There is no universal answer. The right choice depends on a company's stage of development, the composition of its shareholder base, its appetite for transparency, and whether the priority is the established infrastructure and institutional distribution network of a recognised investment exchange, the flexibility and broader accessibility of a directly authorised venue with multiple trading formats, or a specialist auction platform with granular pre-trade transparency and an established track record in periodic private company auctions. The three platforms are complementary rather than directly competing. For many companies, the more relevant question may be when each platform becomes appropriate, rather than which one to choose and there is nothing in the PISCES framework that would prevent a company from engaging with more than one platform over time, or even concurrently, as its needs evolve. With Asset Match's approval adding a third option to the framework, the PISCES ecosystem is maturing quickly, and companies now have genuine choice.

One consideration that applies equally to all three platforms is the temporary nature of the regime itself. The PISCES sandbox operates for five years under modified regulatory arrangements, and the FCA's mandated Market Risk Warning, which must accompany all company disclosures on every platform, states plainly that it will be for the government to decide whether to make the PISCES regime permanent, and that investors will not be able to sell their shares via a PISCES platform if the regime comes to an end. HM Treasury is required to report to Parliament on the effectiveness of the sandbox before the end of the five-year period, and that assessment will inform whether permanent legislation is put in place. Companies considering joining a PISCES platform, and their shareholders, should factor this structural uncertainty into their planning, particularly where liquidity expectations extend beyond the current sandbox period. That said, the broader structural trend towards companies remaining private for longer, and the growing demand for regulated secondary liquidity that this creates, may provide a strong policy rationale for the regime's continuation in some form beyond the sandbox period.

A detailed side-by-side comparison of all three platforms, covering eligibility, trading mechanics, disclosure, transparency, intermediary access, and fees, is available to download here.

This article is for general information purposes only and does not constitute legal advice. If you require advice on PISCES or private company liquidity options tailored to your specific circumstances, please get in touch.