Not every player at the poker table is being asked to show their hand. That, in essence, is the London Stock Exchange’s charge against the FCA’s proposed consolidated tape for UK equities — and the exchange argues the consequences for market integrity, and for London’s standing as a global trading venue, could be severe.

It is a debate that has already generated significant heat, with other participants at the table accusing the exchange of being equally reluctant to show its own cards.

Writing in a blog post, Julia Hoggett, the exchange’s CEO, drew on a card game analogy to frame what she sees as a fundamental flaw in the proposal: some participants want to see what everyone else is holding but keep their own hand close to their chest. She argues that systematic internalisers stand to benefit from the transparency a pre-trade tape would provide without being required to contribute their own pricing and order flow to it. A recent PostTrade 360 feature on SIs shows that having had their post-trade reporting obligations reduced, they are now coming under new scrutiny.

Hoggett argues the FCA must bake robust participation requirements into the tender terms. Once the consolidated tape becomes operational, it will be too late to mitigate any unintended consequences, including the erosion of UK “lit” markets — open venues where bids and offers are visible in real time.

The stakes, she argues, are national as well as structural. If global investors think London is less liquid than it really is, they will price that risk in — or take their capital elsewhere. Should the FCA not move to protect market integrity, Hoggett said it may be necessary to ask the government to intervene.

The warning lands against a backdrop of longer-term concern about the drift of UK equity trading away from transparent, on-exchange venues. The UK now sits near the bottom of international league tables for the proportion of trading that happens on ‘lit’ exchanges a trend driven in part, Hoggett argues, by a regulatory environment that has made it easier than in Europe or the US for trades to migrate to off-exchange mechanisms.

Not everyone, however, reads the tape debate the same way. In a joint position paper, AFME, UK Finance and the Investment Association declared themselves supportive of a pre-trade consolidated tape. They urged the regulator to protect SIs and all venues from mandatory disclosure requirements, arguing that the flexibility to trade away from lit venues gives investors greater choice and supports market resilience.

The FCA is expected to publish its policy on the pre-trade tape tender in July 2026.