Society comments on loss of transparency for UK short-selling
The Society has commented on the FCA's proposed rules to implement the new UK short-selling regime, part of the Edinburgh reforms designed to improve the competitiveness of the UK financial services sector. While the Society recognises the potential benefits for liquidity and price discovery, we also highlight issuer-side concerns around reduced transparency from a move towards anonymised aggregated public disclosures, given the importance of short-position visibility for investor engagement and risk monitoring. We also raise the issue of opaque off exchange trading, as we believe more visibility on that would be helpful.
The Investor Relations Society
Office 605 Birchin Court, 20 Birchin Lane
London EC3V 9DU
Aaron Smith
Financial Conduct Authority
12 Endeavour Square
London E20 1JN
By email: cp25-29@fca.org.uk
16th December 2025
Dear Aaron,
Re: Changes to the UK Short Selling Regime
Thank you for giving us the opportunity to respond to your CP25/29 Consultation Paper on Changes to the UK Short Selling Regime. This response is made on behalf of The Investor Relations Society (‘The Society’).
As the professional body for investor relations in the UK, The Society has proudly supported the IR community since our founding in 1980. Today, our membership includes around 700 IR professionals, representing more than 50% of the FTSE 100 and an ever-growing number of FTSE 250, AIM, and smaller companies, as well as those listed overseas. We also welcome a wide range of advisory firms - from corporate brokers and financial PR agencies to IR consultants, annual report designers, and digital specialists.
Our mission is to promote best practice in investor relations; to support the professional development of our members; to represent their views to regulatory bodies, the investment community and Government; and to act as a forum for issuers and the investment community.
Our response has therefore been primarily constructed through the lens of a corporate issuer, and we set out below our comments relating to Q33 in Chapter 7, which considers the public disclosure aspects of the reformed UK Short Selling regime that are of most relevance to our Members. We also raise the issue of opaque off-exchange trading on which we would welcome engagement with the FCA.
Question 33: Is there anything else associated with the disclosure of ANSPs that you would like to raise?
Firstly, we welcome the Government’s growth agenda and the FCA’s commitment to supporting this under the ‘Edinburgh Reforms’, which are both aimed at improving the attractiveness and competitiveness of the UK financial services sector. Simplified reporting processes and reduced compliance burdens for market participants are positive steps toward a more agile and attractive UK capital market, and we recognise that modernising the UK short-selling regime by removing barriers that might inhibit short-selling and reducing disproportionate costs for firms could bring broader benefits in terms of improved price discovery, liquidity, market efficiency and competitiveness, and bring London’s regime closer to those of other Global markets.
While we acknowledge these benefits, we must highlight concerns from an issuer and investor relations perspective regarding the reduction in transparency that will result from replacing public disclosure of individual short positions above 0.5% with aggregated net short positions (ANSP) above 0.2%.
In our June 2023 response to the FCA's Listing Rules consultation, we mentioned our concern around short position transparency, and suggested that establishing a framework that better enabled companies to identify all short-sellers so that they can engage with them (if they wish) would be a helpful step to further improve market transparency .
HM Treasury’s decision to anonymise this public disclosure represents a significant loss of visibility for issuers because this information has historically provided valuable context for investor engagement and risk monitoring (for example, in relation to activism or hostile M&A). Short interest can signal stock-specific concerns, prompting proactive communication and mitigation of reputational risk. Knowing the identity of large short positions enables the issuer to engage with the short-seller and thus be able to explain to other shareholders the rationale - which is often due to a sector view - rather than a targeted view on a particular stock.
Opaque off-exchange trading
We would also like to take this opportunity to raise the issue of opaque off-exchange trading, as it can be difficult for issuers to see underlying owners when larger positions are being bought on swap. More visibility on this aspect would be viewed as extremely helpful as set out in our recent response to the FCA Liquidity discussion paper. We are aware the FCA is proposing to consult on equity market transparency in 2026, and we would be very happy to meet with the relevant FCA team to discuss these concerns, to help inform that consultation.
We hope you find these comments useful. Please do not hesitate to make contact if you have any questions.
Yours sincerely
Liz Cole
Head of Policy and Communications, The Investor Relations Society
(Email: enquiries@irsociety.org.uk, Tel: + 44 (0) 20 3978 1980)
Published 16 December, 2025