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Finance Bill 2025-26 briefing: CSOP schemes and EMI: PISCES shares

29 January, 2026

The ATT has produced a Finance Bill 2025-26 briefing on clause 16, which allows existing Company Share Option Plan (CSOP) and Enterprise Management Incentive (EMI) option agreements to be varied to include a Private Intermittent Securities and Capital Exchange System (PISCES) trading event as an exercisable event, without jeopardising the tax advantaged status, provided the relevant conditions are met. This will apply to CSOP and EMI share options granted before 6 April 2028.

PISCES is a new, regulated stock market for private company shares. It allows occasional, intermittent trading in private company shares in an accessible, safe, regulated and controlled environment. We gave an overview of PISCES in a previous Employer Focus article.

The ATT is concerned that the draft legislation introduces an arbitrary cut-off date of 5 April 2028. Under current drafting, options granted on or before this date may be varied to permit exercise on a PISCES trading event without loss of tax-advantaged status, while otherwise identical options granted from 6 April 2028 onwards would likely lose that status if varied in the same way. 

The ATT recommends that this easement is extended to at least 6 April 2030, as PISCES is not expected to become permanent until 2030. While this would still involve a cut-off date, it would better align with the government’s policy objectives and allow time for awareness of PISCES to grow.