PISCES for employees: what it means for EMI options, CSOPs and selling startup shares
Last reviewed: October 2026. This guide is general information, not tax, legal or financial advice. Tax depends on your circumstances, so speak to an adviser before you sell.
For many people who join a startup, share options are part of the deal. The problem has always been timing. Options are worth something on paper, but turning them into money usually means waiting for a sale of the company or a listing, which can take ten years or never happen.
PISCES gives employers a new way to let staff sell some of their shares before that moment. The early evidence suggests employee liquidity is one of its main uses. This guide explains what it means for you as an employee or option holder.
The short version
PISCES lets private companies run occasional, controlled trading events in their existing shares.
Employees and directors of the company can be eligible to take part.
The company decides whether and when to run an event, who can join and the price range.
Existing EMI and CSOP options granted before 6 April 2028 can be amended so they can be exercised for a PISCES sale without losing their tax advantages.
Shares traded through PISCES are exempt from stamp duty.
For the full background, read our complete guide to PISCES.
Why employers are using PISCES for staff
Employee share sales are the clearest early use case. In July 2026 Wayve ran an $85 million employee tender through PISCES, letting staff sell vested shares at auction, as reported by Wedlake Bell. Moneybox completed a £45 million staff share sale the same month. We covered both in our reports on Wayve's employee share sale and Moneybox's landmark PISCES sale.
For a company, a controlled sale helps with recruitment and retention. Options become more credible when staff can see a route to cash. It also lets the company manage who comes onto the register, since it chooses which investors may buy.
What happens to your options?
Most employee equity in UK startups sits in one of three forms.
EMI options
Enterprise Management Incentive options are the most common scheme in UK startups because of their tax treatment. Many EMI option agreements only allow exercise on an exit, such as a sale of the company or a listing. A PISCES trading event is neither, so without a change the options could not be exercised to sell into it.
The government has addressed this. Existing EMI options granted before 6 April 2028 can be amended to permit exercise in connection with a PISCES sale without losing their tax-advantaged status, subject to the statutory requirements and the scheme rules. Your employer has to make that amendment. It does not happen automatically.
CSOP options
Company Share Option Plan options follow similar logic. The same amendment window applies to existing CSOP options granted before 6 April 2028.
Unapproved options and shares you already own
If you hold unapproved options, or shares you already own outright, the PISCES amendment rules do not apply in the same way. You may still be able to take part, but the tax treatment can be different and is worth checking before you commit.
Tax points to check
Tax is where most of the value in employee equity is won or lost. These are the questions to raise with an adviser.
Income tax on exercise. Qualifying EMI options granted at or above market value usually carry no income tax on exercise. Unapproved options usually do. Where shares can be sold through an arrangement such as PISCES, they may be treated as readily convertible assets, which can bring PAYE and National Insurance into play.
Capital gains tax on sale. Gains on the eventual sale of your shares are normally subject to capital gains tax, after your annual exempt amount.
Business Asset Disposal Relief. Shares acquired through EMI can qualify for Business Asset Disposal Relief without meeting the usual 5 per cent shareholding test, provided the option was granted at least two years before the sale. The relief reduces the rate of capital gains tax on qualifying gains, up to a lifetime limit. The rate has risen in recent tax years, so check the current figure.
Stamp duty. Buyers pay no stamp duty or SDRT on PISCES trades, which removes a cost that would normally apply to private share transfers over £1,000.
Questions to ask your employer
If your company is considering PISCES, or has announced a trading event, it is reasonable to ask:
Will my options be amended so I can exercise and sell in a PISCES event?
How much of my holding can I sell, and are there caps per person?
What is the price range, and how was the valuation set?
Which investors will be invited to buy?
Who pays the costs of exercise, and is there a cashless exercise option?
How will tax be withheld, if any is due through payroll?
What information will I see before the event, and when?
Things that can block a sale
Even with amended options, other documents can get in the way:
Articles of association may contain pre-emption rights that require shares to be offered to existing shareholders first.
Shareholder agreements may include lock-ups or board consent requirements.
Leaver provisions may limit what former employees can do with their shares.
Companies preparing for PISCES usually review all of these before the first event. If you have left the business, check whether you are still eligible to take part.
Should you sell?
That is a personal decision and depends on your finances, your view of the company and your tax position. Selling part of a holding can reduce risk while keeping some exposure to future growth. It can also crystallise a tax bill earlier than you planned. An independent financial adviser and a tax adviser can help you weigh up the options against your needs and personal situation.
Key points
PISCES gives employees a realistic route to sell some shares before an exit, if the employer chooses to offer it.
EMI and CSOP options granted before 6 April 2028 can be amended to allow exercise for a PISCES sale while keeping their tax advantages.
The company controls timing, price and buyers.
Check income tax, capital gains tax and Business Asset Disposal Relief before you sell.
For news on PISCES trading events as they happen, subscribe to the Tokenising Startups newsletter.
This is general information, not legal, tax or investment advice.
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