FCA consultation: preparing for the UK SSR 2025 proposals

Firms should treat the UK SSR 2025 proposals as highly likely operational mandates. The consultation period closes soon: our analysis below focuses on the core proposed operational changes that require preparedness.

Proposals under consultation

The rules discussed are currently proposals:

• Consultation window: the FCA is consulting on these rules for seven weeks.
• Engagement: the FCA held an event on 6 November 2025 to discuss the proposed changes to their operational arrangements, highlighting the regulator’s commitment to implementing this new regime.

However, the regulator’s intent is clear: major operational shifts are coming. Compliance teams must use this time to map these proposed changes onto their current systems.

5 proposed operational mandates

The FCA is explicitly seeking to reduce administrative burden while clarifying compliance obligations. This requires mandatory updates to reporting, disclosure, and data retention processes.

1. Position reporting: proposed deadline extension

The FCA proposes to extend the deadline for notifying Net Short Positions (NSPs) at or above the 0.2% threshold:

• Proposed deadline: extended to 23:59 T+1.
• Operational impact: this is the most significant relief for firms, granting critical extra hours for accurate calculation and review, particularly for global operations

2. Disclosure: proposed shift to anonymity

The FCA proposes to remove the requirement for named public disclosure (at the 0.5% threshold):

• The proposal: individual NSPs will no longer be publicly revealed. Instead, the FCA will compile all reported NSPs (at 0.2% and above) into a single, anonymised Aggregate Net Short Position (ANSP) for each company and publish this on T+2.
• Operational impact: this proposed shift significantly mitigates the risk of individual firms facing targeted scrutiny or short squeezes.

3. Record-keeping: proposed 5-year data mandate

The FCA proposes a minor but mandatory change to data retention policies:

• The proposal: records demonstrating appropriate covering agreements and arrangements must be held for a minimum of 5 years.
• Operational impact: firms must update their data retention policies immediately to ensure compliance with this 5-year mandate for all short sale coverage evidence.

4. Calculation: proposed clarity on ISC and groups

The rules around NSP calculation are set to become clearer, reducing ambiguity:

• The proposal: the FCA will provide further detail on the accepted methods for determining a company’s Issued Share Capital (ISC), the necessary denominator for the NSP calculation.The approach to reporting positions within corporate groups is also set to change, providing specific guidance to ensure consistency and avoid reporting gaps.
• Operational impact: this clarity should simplify the compliance process by standardising calculation inputs and group reporting structures.

5. Scoping: proposed RSL changes

The regime will see changes to the scope of reportable instruments:

• The proposal: the FCA intends to reduce the number of shares on the Reportable Shares List (RSL). The date for updating the RSL will shift from 1 January to 1 April every two years, aligning with the EU SSR publication to provide the FCA a clear review window.
• Operational impact: compliance systems must be ready to integrate the new RSL format and update schedules, ensuring the correct securities are being monitored against the new rules.

Preparing for inevitable changes

The FCA’s UK SSR proposals are a clear signal: regulatory compliance is evolving, and systems must keep pace. While the changes are currently proposals, they are fundamentally altering key compliance parameters (deadlines, disclosures, calculation basis). Firms that delay system adjustments until the final rules are published will be racing against the clock.

AQMetrics is built for these transitions. Our platform ensures you are ready to implement the highly anticipated changes, including the new 23:59 T+1 deadline, updated NSP calculation logic, and the transition to the new RSL.

Short Selling forms a critical part of our Beneficial Ownership Monitoring solution, alongside Major Shareholding Disclosures, Takeover Panel rules, and Sensitive Industry Monitoring.