PISCES in Practice: QPlay and the Emergence of a New Secondary Market for Private Shares
Introduction
The slowdown in UK IPO activity in recent years has brought into sharper focus a gap in the capital lifecycle of private companies. Listings are increasingly reserved for larger, more mature businesses, while many growth companies, particularly in IP-driven sectors, such as entertainment, gaming, fintech and life sciences, are choosing to remain private for longer.
For these businesses, the challenge is not early-stage capital, but how to provide liquidity to founders, early investors and employees without forcing a full exit or premature listing. In sectors like gaming, where value is tied to IP, release cycles and long-term user growth, the traditional “IPO or sale” model does not always align with how companies scale.
PISCES has been introduced to address this gap. It is a framework designed to enable intermittent secondary trading in private company shares, subject to operator-led trading processes (including pricing and matching mechanisms) and defined participation criteria.
The admission of QPlay via JP provides an early indication of how this market may develop and which sectors may engage first, although its success will likely require a longer period to assess.
From Framework to Reality: QPlay
JP Jenkins, a long-standing facilitator of trading in unlisted securities, became an approved PISCES operator shortly after the London Stock Exchange and moved quickly to bring a company to market.
That company is QPlay, a London-based business founded in 2019 and the developer of Outsmarted, a digital board game incorporating AI-driven adaptive gameplay.
QPlay’s admission illustrates the core features of PISCES:
secondary trading only (no new share issuance);
participation limited to eligible investors;
trading during defined windows rather than continuously; and
a regulated environment offering greater transparency than private bilateral transfers.
PISCES is not a substitute for a listing; it is a controlled mechanism for periodic liquidity.
Eligibility and Positioning
PISCES is aimed at later-stage private companies, not early-stage startups. Applicants are generally expected to meet at least two of the following criteria:
a fundraising of at least £10 million within the last three years;
total assets of at least £20 million; or
annual turnover of at least £10 million.
This positions PISCES squarely between venture-backed growth and public market readiness.
QPlay appears to fit that profile: commercially established, consumer-facing and scaled, but not yet pursuing an IPO.
Exit Route or Liquidity Tool?
The key question is whether PISCES will operate as a genuine exit route or primarily as a tool for partial liquidity. Early indications suggest the latter is more likely.
The QPlay case highlights several advantages:
liquidity without an IPO - shareholders can realise value without the cost and burden of listing;
issuer control - companies retain flexibility over timing and participation;
investor access - eligible investors gain exposure to otherwise inaccessible private companies; and
employee benefits - a clearer path to liquidity may strengthen equity incentives.
However, important limitations remain, including:
no capital raising function;
intermittent liquidity and limited price discovery;
restricted investor base;
ongoing disclosure risk; and
limited participation may constrain demand and therefore pricing outcomes.
PISCES should be viewed as a complementary tool, sitting alongside and not replacing IPOs and sales.
Why This Matters for the Gaming Sector
The timing of PISCES is notable for the gaming sector, following elevated valuations and deal activity in 2020–2021, the market has become more selective, with longer holding periods, fewer immediate exit opportunities and increasing cost constraints. While strong studios continue to attract interest, liquidity events are often less predictable.
PISCES introduces an alternative. Founders can access partial liquidity without losing control, investors can realise value incrementally and employees may gain a more credible route to monetising equity.
Conclusion
The admission of QPlay marks an important early milestone for PISCES. It shows that the framework can support real transactions in sectors where traditional exit routes may not align with how businesses grow.
Rather than replacing IPOs or sales, it provides something that has long been missing: a structured, repeatable route to liquidity without requiring a full exit. It will be interesting to see whether, and to what extent, others follow suit, with success to be judged in the fullness of time.