Overview
FundApps has prepared for the upcoming changes to the United Kingdom (UK) Short Selling Regime (SSR). From 13 July 2026, the Financial Conduct Authority (FCA) will replace the current exempt-share model with a Reportable Shares List (RSL) model.
Under the old regime, UK-listed securities were generally in scope unless they appeared on the FCA Exempt List (or a client's Custom Exempt List).
Under the new regime, only issuers and ISINs identified on the FCA Reportable Shares List will be in scope.
To support the transition between these approaches, we have released updated versions of the existing rules, along with a new rule, SSR Equity: United Kingdom - New Exits, which are designed to identify issuers moving out of scope.
What to Expect During the Transition
The tables below summarise how the transition will impact results.
UK SSR Transition Overview
The UK SSR Rules will continue to be split into Management and Non-Management versions. However, from 13 July 2026, the FCA will replace the exempt-share model with a Reportable Shares List (RSL) model.
Date | Scope Model | Alert Changes |
10 July 2026 | Current exempt-share regime | RSL Warning alert and RSL Transition Disclosure alert added.
Existing Exempt Disclosure alerts remain active. |
13 July 2026 | FCA Reportable Shares List | Exempt Disclosure alert removed and replaced by RSL Exit Disclosure alert. |
14 July 2026 onwards | FCA Reportable Shares List | RSL Exit Disclosure alert remains active. |
UK SSR Alert Examples – What to Expect
Scope Model | Holding | Included on RSL? | Alert |
10 July 2026:
Current exempt-share regime | No threshold change | Yes | Info |
| No threshold change | No | RSL Exit Warning |
| Cross threshold | Yes | Threshold Disclosure |
| Cross threshold | No | Threshold Disclosure - RSL Exit Advisory |
13/14+ July 2026:
FCA Reportable Shares List | Cross threshold | Yes | Threshold Disclosure |
| Rule Value = 0 | Yes | Zero Disclosure |
| Rule Value = 0 | No | Exit Disclosure |
Note: The examples above are illustrative only. Actual alerts depend on position changes, Issuer status, and the applicable UK SSR rule version.
10 July 2026
The exempt-share model remains in effect, though disclosure time is extended to 23:59 on T+1 from 15:30 per Section E6.6(b) of the memo.
The first version of the SSR Equity: United Kingdom - New Exits rule takes effect.
This rule identifies issuers that appear to be within the scope of the current regime but whose ISINs are not on the Reportable Shares List as of 10 July 2026.
These alerts are intended to highlight positions that may be treated differently under the new regime.
If any such issuers are identified, one of the following transition alerts will appear in the results for 10 July 2026:
Warning (for any result below a disclosure threshold); or
Disclosure (if a disclosure threshold has been crossed).
Note that the treatment of threshold crossings occurring on 10 July 2026 for issuers that do not appear on the FCA Reportable Shares List as of the 13 July 2026 update has not been made entirely clear.
To be conservative, the system will generate threshold-crossing disclosures on 10 July 2026, as described above. Clients should review any such disclosures against the FCA Reportable Shares List published on 13 July 2026 before filing.
13 July 2026
SSR Equity rule scope changes to include only issuers and ISINs identified on the FCA Reportable Shares List. The FCA is scheduled to release an update to the list at noon on 13 July 2026 (UK time).
A new type of Exit Disclosure alert replaces the Exempt Disclosure alert for SSR Equity rules returning a zero value. The Exempt alert identified ISINs added to an Exempt List, whereas the new alert identifies issuers removed from scope by the FCA.
The transition alerts used on 10 July 2026 are no longer required and are removed.
14 July 2026 Onwards
The third version of the SSR Equity rule becomes active together with the second version of the New Exits rule. Both compare the FCA Reportable Shares List for the current NAV Date with the previous day's list to identify issuers that have been removed from scope.
Other Things to Know
Exchange Traded Funds (ETFs)
The FCA has set out certain requirements regarding when to look through to the underlying components when holding positions in the units of funds managed on a discretionary/active basis. See E.6.1(e) of the aosphere memo for more information.
FundApps assumes that clients do not provide components for units of actively managed funds because publicly available data is limited. If this assumption is not correct, please let us know, and we will work with you to update the rule accordingly.
In-Scope Shares Not Admitted to UK Markets
The FCA’s Reportable Shares List only includes ISINs for shares admitted to trading on UK markets. In the Policy Statement, the FCA states:
“A large majority of the companies that we include on the list will have every class of share admitted to trading on a UK trading venue.”
But the FCA also notes that exceptions may exist:
"Persons should also consider if they have any positions in shares issued by such companies which are either not admitted to trading on a UK trading venue, or not admitted to trading on any trading venue, as they are not included on the list."
Given the possibility of such exceptions, we have made it possible for clients to indicate that a specific issuer is in scope even if its ISIN does not appear on the RSL.
To do so, clients may manually set a value for IssuerNameSSRGB. Please use caution, as any value supplied here must exactly match the issuer name on the GB Reportable Shares Regulatory Data list.
This list can be found by navigating to Monitoring > Shareholding Disclosure > Rules > Regulatory Data > GB Reportable Shares.