Regulatory Friction: Unpacking UK Listing Rule Discrepancies
The UK regulatory landscape for public markets recently underwent significant changes with the introduction of the Public Offers and Admissions to Trading Regulations (POATRs) regime and revised UK Listing Rules (UKLR) on 19 January 2026. While the intent was to streamline processes, particularly for frequent issuers, the immediate aftermath has revealed practical inconsistencies, causing unnecessary complexity for market participants.
The New Framework: 60-Day Notification
A core change introduced by the new POATRs regime is the requirement under PRM 1.6.4R for issuers to notify a Regulatory Information Service (RIS) of any admission to trading within 60 days. This provision was designed to be efficient, allowing issuers who frequently admit securities to trading to group these events into a single, comprehensive notification rather than publishing detailed updates each time. The aim was clear: support proportionate transparency without creating an administrative burden.
Unintended Overlap: Confusion on the Ground
Despite this clear intention, the implementation has not been seamless. Issues have emerged due to potentially overlapping requirements within various UKLR provisions, specifically UKLR 6.4.4R(4) and its equivalents in other chapters. These rules mandate that listed companies notify an RIS "as soon as possible" regarding the results of any new issue of equity securities or public offer of existing equity securities.
This "as soon as possible" clause clashes directly with the new 60-day window, creating ambiguity. Furthermore, the confusion is compounded by the simultaneous removal of block listing rules (UKLR 20.6) on the same date. Issuers who previously relied on exemptions for block listings now find themselves navigating a fragmented set of obligations, contrary to the spirit of simplification.
The Market Participants Group (MPG), a senior forum for financial market participants to discuss relevant themes with the Bank of England’s Monetary Policy Committee, often serves as a conduit for such market feedback 1. The current situation underscores the tension between regulatory theory and market practice.
Regulatory Acknowledgment and Course Correction
Recognising this unintended friction, the Financial Conduct Authority (FCA) has acknowledged the problem. In a recent statement, the FCA clarified that it was not the policy intention to burden issuers with additional or duplicative announcements 2. The goal was precisely the opposite: to simplify, not complicate.
To rectify this, the FCA intends to consult shortly on removing UKLR 6.4.4R(4) and equivalent provisions across other UKLR chapters. The proposed outcome is to leave issuers subject only to the 60-day notification requirement under PRM 1.6.4R for admissions to trading, thereby eliminating the current redundancy.
Immediate Relief: The Forbearance Stance
Crucially, the FCA has also announced a temporary supervisory approach to mitigate immediate concerns. Until further changes are announced:
- The FCA will not take supervisory or enforcement action where issuers, previously granted a block listing under former UKLR 20.6, do not make notifications under UKLR 6.4.4R(4).
- This forbearance applies specifically to new issues or public offerings of securities that:
- Were covered by the former block listing.
- Had not been issued or offered before UKLR 20.6 was revoked on 19 January 2026.
- Are used for the same purposes as the original block listing.
This pragmatic interim measure offers a necessary pause, reflecting a clear understanding that the current rules, while technically in force, do not align with their stated policy objective 3.
The Path Forward: Prioritising Clarity
The journey to a truly streamlined and efficient listing environment requires more than just new rules; it demands coherence and practical application. The current scenario highlights the critical need for regulatory bodies to continuously engage with market participants and swiftly address unintended consequences. The FCA's prompt acknowledgement and commitment to consultation are positive steps towards restoring clarity and ensuring that regulatory frameworks genuinely facilitate, rather than hinder, market operations.
Key Takeaways
- POATRs and UKLR changes on 19 January 2026 introduced a 60-day notification period for admissions to trading (PRM 1.6.4R).
- Overlapping requirements (e.g., UKLR 6.4.4R(4)) for "as soon as possible" notifications created confusion, particularly after the removal of block listing rules.
- The FCA acknowledged this unintended consequence, affirming that duplicative announcements were not the policy intention.
- FCA plans to consult on removing the problematic UKLR provisions, leaving only the 60-day rule.
- Temporary forbearance is in place for issuers who previously held block listings, providing immediate relief from conflicting notification requirements.
