New PISCES market for unlisted company shares

1 September 2025

Corporate Partner Penny Paddle was recently featured in GovComp Magazine discussing PISCES (Private Intermittent Securities and Capital Exchange System) – a new platform for trading unlisted company shares that is set to launch later this year.

The article explores the opportunities PISCES offers for private businesses. It allows shareholders – including founders, early investors, and employees – to buy and sell shares more flexibly without the costs and regulatory burdens of a full stock market listing. For directors, this creates new considerations around disclosure, governance, and ensuring adequate resources are in place to meet investor expectations.

The article highlights the importance of legal and governance planning before participating in the market.

Penny explains the various considerations for unlisted companies, including how the company is formed.

“The majority of private or unlisted public companies are likely to have either Articles of Association or Shareholders’ Agreements in place that contain provisions, such as pre-emption rights which will need to be removed. Prior to applying to trade their shares through a PISCES operator, it will be important for companies to have these documents legally reviewed and updated to ensure PISCES compliance.”

With lighter-touch disclosure requirements and the ability to choose the frequency of trading events, PISCES aims to provide a more flexible, efficient market for unlisted company shares – while still requiring careful preparation to ensure compliance and protect company interests.

You can read the full feature in GovComp Magazine here.

Penny Paddle
Partner - Corporate and Commercial
Penny Paddle is a Partner Solicitor at Spencer West specialising in Corporate and Commercial matters.