Written submission from London Stock Exchange Group (FRE0055)
Financing the real economy – LSEG Submission
About LSEG
LSEG is a leading global financial markets infrastructure and data provider. Our four business divisions – Data & Analytics, FTSE Russell, Risk Intelligence and Markets – enable companies and economies around the world to fund innovation, manage risk and create jobs.
Our markets infrastructure - including LCH, recognised by G20 nations as globally systemic, and our FX and rates businesses - plays a critical role in underpinning financial stability and liquidity across jurisdictions. From the gilt market to eurozone debt and repo, LSEG’s platforms are central to the functioning of global capital markets.
We are well known for our flagship venue, the London Stock Exchange, which remains the most international market in the world and the number one exchange in Europe for IPOs and equity capital. But the depth and breadth of our business goes far beyond our markets in London. We deliver financial data, analytics, news and index products to more than 40,000 customers in 190 markets. We have a team of 24,000 people in 70 countries.
Through these roles and as the London Stock Exchange, we are deeply committed to supporting the UK’s ambitions for capital formation and economic growth. Our work aims to ensure the UK is the best place to start, grow, scale and keep companies that can drive growth and prosperity in the UK as well as to attract overseas firms to list in London and to channel international investment into the UK economy. This reflects our confidence in the UK not just as a financial centre, but as a hub for innovation, sustainability, and real-economy impact.
Executive Summary
Directing higher levels of capital towards UK investments is a vital prerequisite for boosting growth. By doing this, the UK can create a stronger funding continuum, ensuring companies can start, scale, list, and stay listed in the UK. This ‘conveyor belt’ or ‘funding continuum’ of capital will help the UK to capture the full potential of its robust start-up ecosystem.
Government must create the right policy structures to incentivise capital to be put to best use for both individuals and the economy. The narrative that the UK has an investment gap because it is not an attractive place to invest and does not have investable assets is inaccurate and does the country a disservice. Rather, policy failure has pushed capital away from UK equities over the past two decades. Whether it be the domestic allocation of pension funds, the balance of tax incentives for investment, or reviving a culture of retail investment, the recommendations throughout this document share a common theme – fuelling the growth our economy needs through investment. You can engineer the perfect car, but simply put, without fuel, it will not move. These recommendations include:
Is British investment too low - and why?
Why has UK investment lagged so far behind peers for decades?
In a global economy where the US has individual state by state incentive structures, the Inflation Reduction Act and requires US domiciliation both of its companies and increasingly the companies using its capital markets if they wish to thrive on their markets; the EU has the single market and the EU Chips Act; and where India and China have restrictions to favour their home markets, the competitive environment for incentives to invest, grow and remain in the UK have changed radically, whilst our approach to incentives has not.
Arguably the biggest driver of a downturn in UK investment was the policy decision to incentivise closing out Defined Benefit Pension Schemes, the largest open-ended pools of value/growth creating capital a country has and not replacing it with a policy framework to maintain the level of risk capital investing in the economy and match incentives to UK investment. Over the last 30 years, policy decisions have resulted in risk capital investment being removed from the economy. This timeline of policy decisions includes:
We believe that there are likely to be numerous examples of these sorts of structures where the UK has not ultimately used the benefits it is providing to ‘back itself’ – it is akin to expensively heating your house and then leaving the window open in winter. Arguably we have had a fiscal, public policy and regulatory stance of exporting capital to subsidize the cost of capital of other markets including the S&P500 - the market with whom home grown/UK people employing companies compete.
For example, when it comes to EMI (Enterprise Management Incentive) schemes, the UK partially recognised the need for a UK focus in 2020, when it introduced a requirement that for a company to qualify for an EMI scheme it must have a permanent establishment in the UK. Unfortunately, that only applies during the life of the EMI scheme but fails to address what happens when the benefits of the EMI scheme are taken advantage of through for example a sale or the listing of the business. The simple act of incentivising UK management teams to be able to use EMI only where they retain a UK base in their qualifying event – in the case of a trade sale by retaining UK incorporation or substantial activity and in the case of a listing by doing so on a PISCES venue, Aquis, AIM, or the London Stock Exchange, would immediately support the benefits of that company’s growth redounding to the UK. It is also possible it could be done through HMRC guidance rather than a complex legislative process.
There is also a cultural aspect to this challenge; UK investment has remained persistently low in part because of a national preference towards investments that are stores of value such as cash savings and property, rather than creators of value, such as through investment in equities. Unlike countries where individuals and institutions more readily channel capital into domestic stock markets to support business growth, many in the UK have long exhibited a tendency to treat housing as the primary vehicle for wealth accumulation and security, with savings accounts and cash ISAs often prioritised for their perceived safety despite lower real returns. This extreme overcaution reduces the flow of capital into growth driving endeavours such as equity markets, limiting funding for innovation and expansion in UK companies, and therefore ultimately contributing to weaker long-term productivity and growth.
It should be noted that an individual, a company or a country’s willingness to take informed risk should also be commensurate with a capacity to take risk. By starving the UK economy, individuals and companies of available risk capital, it by definition stunts the ability of the economy to take the necessary big bets on backing itself or themselves. The availability of long-term patient risk capital has been the marker of the history of each one of the Magnificent 7 companies.
It should also be noted that the availability of domestic risk capital in an economy is directly correlated with investor expectations of the future value of companies in that economy.
To use a parallel, if you are buying a house that has not been invested in for several years because the owners did not have available capital to invest or indeed because the spare capital they did have to invest had been directed to some other purpose (in the case of companies this may be dividends which provide near term yield for investors but potentially at the expense of longer term growth, or a lack of available capital for investors to use to buy that company’s shares), then it is entirely likely that you will only be prepared to pay a lower amount for that house than the same sized house on the same street where the owners had had spare money to spend on its upkeep. To continue the analogy, the other owners of the houses on the street that now contains a less smart looking property, may also then be impacted by the relative prices and perception of the smartness of that street in the valuation of their own houses.
What is the scale of the investment shortfall, and how does it affect productivity, growth and wages?
Underinvestment in the economy has been a significant dampener on growth. Since the global financial crash the UK has underinvested both in absolute terms and compared to our G7 peers with our Investment/GDP ratio around 17 to 18% compared to our peers of 20 to 25%. This underinvestment gap is around £100 billion.
ONS data demonstrates that the UK economy has underperformed since then. There has been no growth in real wages or real GDP per capita and small growth in productivity. ONS data also shows that real GDP per capita was £27,218 in 2007 and £27,819 sixteen years later in 2023, so no annual growth. Average wages in the UK would have been £10,000 per annum higher if they had matched their performance prior to the GFC. The Capital Markets Industry Taskforce commissioned a Report entitled the Capital Markets of Tomorrow which estimated that the UK needs to invest around an additional £100 billion of productive capital per annum for ten years, so £1 trillion in total, to deliver 3% annual growth in real wages and real GDP per capita.[1]
As described above, this is in part driven by UK pension funds steadily shifting away from equities and towards bonds over the past few decades, a move driven by regulatory pressures, accounting changes, and a desire to minimise short-term volatility in funding positions. While bonds offer greater certainty in matching liabilities, this shift has significantly reduced the amount of long-term patient risk-capital flowing into UK businesses. New Financial analysis has shown that in 1997, UK pension funds held 73% of their portfolios in equities and 15% in bonds. These figures now stand at 34% and 43% respectively, a significant reversal.[2]
This is worsened by pension funds particular aversion to UK equities – which has fallen to a mere 4.4%, compared to an international average of 10.1% for other countries investing in their own domestic markets. The overall allocation to equities by UK pension funds of 30% is lower than every market except Canada, Denmark, and the Netherlands[3]. Data collected in 2023 on a selection of overseas pension funds showed that for example, Japan’s government pension investment figure sits at nearly 50% and Italy’s public pension ENPAM sits at 40%[4],Resulting in what UK patient risk capital we do have in Defined Benefit pension schemes being more readily used to reduce the cost of capital of non-UK companies than UK based and listed companies.
How does the UK’s savings rate, corporate structure, or tax regime affect capital formation?
All these factors come together to influence capital formation, and considerable progress has been made in recent years on many aspects this agenda, including Mansion House reforms and the introduction of PISCES, which will greatly improve the UK’s competitiveness. However, more needs to be done to grow these pools of capital. There are several areas where the UK can focus on structural reforms (LSEG’s specific recommendations on pension reforms are outlined in the following question):
Supporting Scale Ups – AIM and Business Relief: The UK has a superb start-up ecosystem. We have some of the world’s best universities and lead in emerging sectors like fintech and life sciences. This is not an accident, the early stages of the scale-up journey work well because the UK has policies in place to help provide companies with a ‘conveyor belt’ of capital as they grow by providing incentives for investors to back them when they are small. Schemes such as the Enterprise Investment Scheme and Venture Capital Trusts have had a significant impact in fostering UK start-ups. They make an important contribution to the ‘conveyor belt’ of funding for scaling companies. In the 2023 Autumn Statement the sunset clause for EIS and VCT schemes was extended, pushing the deadline for tax relief eligibility from 2025 to 2035. This had a reassuring effect on investor confidence, by providing that level of certainty needed to make long term investment decisions.
Capital Markets like AIM have been a core component of the UK’s success in fostering scaling companies. Since its inception in 1995, AIM has supported more than 4,000 companies to raise over £138 billion. AIM continues to lead as Europe’s leading growth market, over the last 5 years, 54% of all capital raised on European growth markets has been on AIM.
However, in recent years the AIM market has come under significant strain. A combination of net outflows of capital, the reduction in the number of smaller quoted companies, fewer IPOs and lower liquidity has started to undermine this important section of the public markets. AIM has contracted from 819 companies with a combined value of £131bn at the end of 2020 to 634 companies valued at £70bn today.
This is in part due to changes to tax relief changes. For qualifying companies admitted to AIM, there is a tax relief called Business Property Relief, an inheritance tax relief that encourages investment in growth areas. It is a key part of the ecosystem; assets in AIM-focussed IHT products total around £7bn, the current market cap of AIM is £66.5bn meaning this represents around 9% of the current size of the market.
Business Relief was cut in October 2024 from a 100% relief to 50% which has created speculation and uncertainty that it will be reduced further or scrapped entirely at the Autumn Statement. Given that such a large proportion of the investment in the market is through AIM-focussed IHT products, this would be an extremely detrimental policy decision. AIM related IHT reliefs are estimated to cost the Treasury £185m[5] in forgone tax revenue, but support businesses which directly provide a total of £35.7bn in gross value added to UK GDP and £5.4bn in tax[6]. This policy is a piece of the interlinked group of policies which has created the UK’s successful track record on start-ups. Removing it would raise marginal revenue, but risk significant negative consequences, including a loss of growth which would have a net negative effect on treasury revenues.
Instead, the government should confirm that there will be no further change to the relevant tax reliefs for the length of this Parliament and confirm the availability of Business Relief on growth market shares until 2035, putting it on the same footing as EIS and VCT.
Recommendation:
Retail investment: Historically, the UK has had a strong tradition of direct retail investment in shares. However, retail share ownership levels have fallen dramatically with the number of households who directly own shares in the UK more than halving in the last 20 years from 23% to around 11%.[7] The popularity of the cash ISA is a significant factor, which is now one of the UK’s most popular savings products. Savers have £300bn invested in cash ISAs, a large pool of capital which could in part support productive investment, bringing better returns both to savers and the wider economy. Indeed, when ISAs were first introduced, only 30% of the total allowance could be held in cash, which may be a more optimal arrangement. The current approach, where savers can choose to use their full ISA allowance for cash savings, was only introduced in 2014.
There is an opportunity to encourage greater retail share ownership, whilst maintaining the cash ISA product. There is currently a separation between cash ISAs and stocks and shares ISAs, which if removed could help savers move more fluidly between allocations. This would encourage a greater proportion of savers to increase their share ownership and move away from overexposure to cash.
The ISA regime was introduced to encourage long-term household saving and investment by providing a tax-advantaged framework for individuals to accumulate wealth. Within this regime, however, the parallel existence of cash ISAs alongside stocks and shares ISAs (when combined with policy decisions that have reduced retail investors’ access to advice (something the FCA is now addressing) has had the unintended consequence of lowering the proportion of the population engaging in genuine investment activity. Indeed, when ISAs were first introduced, only 30% of the total allowance could be held in cash, which may be a more optimal arrangement. The current approach, where savers can choose to use their full ISA allowance for cash savings, was only introduced in 2014.
Cash ISAs are functionally equivalent to standard bank or building society savings accounts, with the additional benefit that the interest generated is free from income tax. This design feature has led many households to treat ISAs primarily as a tax-sheltered extension of cash savings, rather than as a gateway into capital markets. By contrast, stocks and shares ISAs channel funds into equities, bonds, and collective investment vehicles, thereby mobilising household savings to support productive economic activity. The argument that may be raised by Building Societies that these cash ISAs support the cost of mortgages for the UK in our view also misses the point. The UK is over-indexed on cash and housing as a percentage of its total assets and deploys and incentivises the deployment of too little risk capital. Such position appears to aim to perpetuate this problem for the UK economy.
The separation of these products within the ISA system has created a structural bifurcation that shapes saver behaviour. Empirical evidence consistently shows that equities and other market-based assets generate higher average returns than cash deposits over the long term, albeit with greater short-term volatility. However, by offering cash ISAs within the same tax-advantaged framework, the system reinforces a perception that holding cash is the “default” or “safer” form of saving, while investment in capital markets is optional and risk-laden. This framing discourages participation in productive investment and leads to suboptimal outcomes for households, whose wealth is eroded by inflation, as well as for the wider economy, which is deprived of a deeper pool of long-term investment capital.
The existence of cash ISAs therefore has a twofold negative effect. At the micro level, households are less likely to build resilience against inflation and less able to accumulate wealth over the long term. At the macro level, the diversion of household savings into low-yield cash holdings limits the growth of domestic capital markets and reduces the potential for investment-driven economic expansion.
In this context, the continued maintenance of cash ISAs as a distinct and equally promoted component of the ISA system appears misaligned with the broader policy goal of fostering long-term investment. A re-examination of the ISA framework may therefore be warranted, with consideration given to how incentives and product design could better channel household savings towards productive assets rather than passive cash accumulation.
Recommendation - ISA reform to increase retail investment: Simplify the ISA framework to remove the multiple types of ISAs which are currently confusing and have a single cash/stocks and shares interface so money can flow from one to the other easily.
Stamp Duty: The UK’s stamp duty actively penalizes UK retail investors and their pension funds for investing in UK listed companies on the Main Market but does not tax purchases of shares in overseas companies. A 0.5% stamp duty is due on UK shares, but not on overseas shares, meaning that retail investors are taxed to invest in Aston Martin for example, but not in Tesla.
This has real world consequences, for example, inclusion in the FTSE 100 index is a major selling point for large companies considering listing in the UK, but it is subject to a sufficient level of trading occurring in our market. Metlen, a company recently listed on the London Stock Exchange, has seen a significant proportion of its shareholders continue to trade via the Greek Central Securities Depository. 70% of shareholders elected to keep their shares in the Greek CSD, rather than via Crest on the LSE. This behaviour appears to be driven by the desire to avoid UK stamp duty on share transactions. This posed a risk to Metlen’s eligibility for inclusion in the FTSE 100 index, which requires a minimum level of trading to occur on UK venues. Metlen was included in the FTSE index in September 2025 – but it need not have been at risk. We use this example as it is a tangible recent demonstration of retail investors changing their behaviour in the face of the stamp duty – potentially materially to the detriment of the functioning of and participation in the UK capital markets.
Whilst government revenues remain under significant pressure, there needs to be a clear path to gradually reducing stamp duty on shares over time, starting with the measures that will provide greatest growth benefit. There are a range of potential models for the UK to introduce a cost-effective Stamp Duty Reserve Tax (SDRT) exemption on UK shares. For example, exempting SDRT from IPOs for an initial period of time and for retail investment in Stocks & Shares ISAs.
Recommendation - Stamp Duty reform: Introduce an exemption for trading occurring on ISAs (£85m cost, which is already minimal and would be offset by as little as +2.5% increase in transactional volumes, which would be easily satisfied through measures to encourage greater pension fund capital to be invested in UK equities) and an from incurring stamp duty charges for any newly listed stock for 3- or 5-years post IPO.
What international models or policy frameworks offer lessons for the UK?
The UK can learn from many of its international peers which have higher rates of domestic investment. While the policies that drove these situations differ, they led to a situation where institutional capital does benefit their domestic economies. UK pension schemes now hold only 34% of their investments in domestic and global equities compared to 50% in the US. Of that 34%, UK pension schemes are only allocated 4.1% to UK equities. By contrast, UK pensions now hold 62% of their investments in fixed income, real estate, and other assets, compared to their peers in the US which hold only 32% in these assets.[8]
Reforms to date have focused on technocratic policy changes to support capital markets, which are beginning to bear some fruit; however, it has not addressed some of the more structural and somewhat cultural components of a successful capital market that can genuinely drive growth:
1) Materially increasing the deployment of domestic risk capital by being politically and culturally willing to use domestic incentive structures to do so. It is not the absence of levers still at the country’s disposal so much as the seeming lack of willingness to use them.
2) A real focus on enabling retail investor participation and encouraging it culturally – including by being much clearer about the opportunity cost to communities of not investing.
3) A recognition that the structure of available investable capital in the UK needs to be appropriately weighted between stores of value and drivers of growth in order to drive growth. The UK has not had a target structure to aim for and has therefore seen ever more capital directed towards cash and housing and increasingly less directed towards risk capital investments that drive economic growth.
The suppliers of capital
Do UK institutional investors allocate sufficient capital to productive enterprise - and if not, what are the underlying reasons?
The UK has the second largest pool of long-term capital in the world, but allocation to UK equities is down from over 50% to 4.1% of assets over the last 25 years.[9] Channelling more investment into the UK would support more companies, contributing directly to employment, exports and tax receipts. The progress to date and introduction of the Pensions Schemes Bill is welcome, but further steps are required if we are to see UK domestic investment levels reach that of international averages.
The competitive environment to invest in, grow and remain in the UK has changed radically, whilst our approach to incentives has not. As a nation, the UK provides pension tax advantages worth over £48bn, and yet the Government sets no expectations that any pension fund investments rebound to the UK, despite it being where savers live and will most likely retire. Unlike most of its major G20 peer nations, the UK has not been as laser focused on how the provision of tax relief or support, or broadly our tax structure, can be used to actively incentivise economic activity to remain in the UK. Or indeed, where if tax relief are being provided the nation might place specific requirements on the actors receiving them – even if the levers used are achieved through other policy means.
Crucially, over time, the UK has instituted policies that reduced the availability of long-term mutualised risk capital deployment (i.e. by shuttering many open Defined Benefits schemes) and did not replace them with anything likely to provide the same benefit to the economy and also removed incentives that supported greater investment in UK equities/UK productive risk capital by pension funds. These changes made it wholly rational for pension funds to derisk their asset profile and increasingly, where UK pension funds do own equities, they are adopting a global weighted portfolio approach - which reduces investment in UK equities in favour of overseas equities and compounds a problem that was created by the changed structure of our pension funds initially.
This harms the UK’s domestic markets; studies show that with current trends the UK will experience outflows of £19bn from its equity market by 2030. Whilst consolidation of LGPS is a hugely welcome step in this regard, as would be consolidation of DC schemes – there remain a large number of very small private DB schemes that could also be further consolidated for the benefit of their members and for the economy. If, and only if, these structural changes are matched with greater incentives to invest in UK risk assets.
What constraints do pension funds, insurance companies, and sovereign wealth funds face when investing in UK growth assets?
The answer to each of those questions is different. Fundamentally, the UK has made policy choices that have structurally changed its capacity to deploy domestic risk capital. For Pension Funds it is the closure of open DB schemes, the removal of incentives to invest in UK assets (i.e. the removal of the dividend tax credit), the regulation that has overly focused on cost not net returns resulting in pension funds buying passive tracking indices (often massively overweight the US) rather than actively investing in growing UK companies.
For private DB schemes that might wish to go into buy-out (i.e. become an insurance product) then it is the strict matching adjustment rules in Solvency UK that restrict their freedom of investment. The regulation actively incentivises open corporate DB schemes to shutter and derisk and a great many do so by selling to Pension Insurers – who are then subject to much stricter rules. This move has, as with the shuttering of DB Pension Schemes, fundamentally altered the nature of our pension investing as a nation – from open, mutualised pools of long-term risk capital, to closed, derisked, much more capital-intensive matched portfolios.
Recommendation - Default UK-weighted funds: Require DC default funds to have a ‘UK weighting’ of 20% or 25% of their total investment in equities, with the option for individuals to opt out.
This will however set the default level of UK’s domestic investment closer to that of international competitors. Doing so would deepen market liquidity, providing businesses with access to deeper, more reliable sources of capital at competitive valuations. By channelling pension savings into equities by default, the UK can support stronger capital markets, encourage more IPOs, and ultimately foster greater economic dynamism.
What reforms could enhance the UK’s attractiveness as a destination for global capital, particularly from patient or long-term investors?
The recommendations made throughout this document (UK-weighted default funds, ISA reform, stamp duty changes, business relief certainty) are targeted at creating a solid base of incentives for UK domestic investment. These moves are vital, not just because they are within the government’s gift, but also in signalling to investors that the UK is focused on deploying capital within its own economy. Paired with wider reform, such as supply-side reforms to infrastructure development, investors will be given greater confidence. Simply put – if we don’t back ourselves as a nation, why should capital from overseas do so?
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[1] Capital-Markets-Of-Tomorrow-report.pdf
[2] Unlocking the capital in capital markets
[3] Comparing the asset allocation of global pension systems
[4] Capital Markets Industry Taskforce (CMIT) Letter-to-the-CHX-Pensions.pdf
[5] Summary of reforms to agricultural property relief and business property relief - GOV.UK
[6] https://www.grantthornton.co.uk/insights/report-the-economic-impact-of-aim-companies/
[7] The UK investment gap: £430 billion in cash savings not invested by UK adults | Barclays
[8] CMIT - HMT Letter - Mar 2023
[9] Comparing the asset allocation of global pension systems