EEA Exchange Segments — ISA Eligibility

Summary: ALXP is an MTF operated by Euronext Paris, an HMRC-recognised stock exchange. Since the 2013 ISA rule change, eligibility rests on admission to trading on a market of an HMRC-recognised exchange, not on the “listed” definition. ALXP is also registered as an SME Growth Market under MiFID II with harmonised rulebooks.

• HMRC country page (France): shows “Euronext Growth Paris” under “Not listed” — that label applies to the separate listing test (ITA 2007 s1005), not to ISAs.
  HMRC recognised exchanges — France
• ISA manager guidance: post-2013, shares can qualify if admitted to trading on a market of an HMRC-recognised exchange in the UK/EEA.
  HMRC ISA manager guidance
• Euronext SME Growth status:
  Euronext — SME Growth Market status
• AMF background on RMs/MTFs:
  AMF: regulated markets & MTFs

Disclosure to clients: HMRC has not published a single line explicitly stating “ALXP is ISA-qualifying”. The treatment follows the 2013 “admitted to trading” change plus ALXP’s SME GM framework and Euronext Paris being an RSE.

Summary: Euronext Access is AMF-authorised as an MTF, but authorisation alone does not satisfy HMRC’s ISA test. HMRC expects qualifying markets to operate as a functional stock exchange — i.e., meaningful admission standards, ongoing reporting, investor protections, and supervisory oversight comparable to a listed environment. Access has a deliberately light, entry-level rulebook (even with Access+), and is not an SME Growth Market. On that functional basis, we treat Euronext Access as not ISA-qualifying. By contrast, Euronext Growth operates with harmonised SME GM obligations and typically meets the post-2013 “admitted to trading on a market of an RSE” test.

• AMF authorisations (France): confirms Access is an authorised MTF; this evidences regulation but not HMRC ISA eligibility by itself.
  AMF — Regulated markets & MTFs
• HMRC country page (France example): lists Euronext Access Paris under “Not listed” — that label is for the listing test, not ISAs.
  HMRC recognised exchanges — France
• Access rulebook (Book I): Access is an MTF with more flexible admission/continuing requirements; Access+ is optional.
  Euronext Access Rulebook — Book I (PDF)
• Choosing a market (Euronext explainer): Access positioned as the simplest entry route; Growth above it with stronger obligations.
  Euronext: Choosing a market
• ISA manager guidance (context): ISA eligibility via “admitted to trading on a market of an HMRC-recognised exchange” (post-2013 admission test).
  HMRC ISA manager guidance

Policy point: AMF authorisation shows Access is a real MTF, but HMRC’s functional “operates as a stock exchange” test still fails here. Until HMRC explicitly confirms otherwise, we will treat Euronext Access as ineligible for ISAs.

Summary: First North venues are MTFs operated by HMRC-recognised exchanges (the main Nasdaq Nordic exchanges). Post-2013 ISA rules focus on admitted to trading on a market of an HMRC-recognised exchange. Many UK platforms accept First North under this logic (and this sets precendent), particularly where the specific First North segment is registered as an SME Growth Market with defined admission and continuing obligations.

• HMRC country tables (Nordics/Baltics): main markets “Listed”; First North appears under “Not listed” (listing test). ISA test differs.
  HMRC “shorter tables”
• Nasdaq First North overview:
  Nasdaq First North
• ISA manager guidance (admission test):
  HMRC ISA manager guidance

Risk disclosure: HMRC has not published a line-by-line ISA statement for First North, but operator=RSE + MTF=market of that RSE + SME GM status + industry acceptance underpin inclusion.

Summary: The Baltic First North venues are MTFs operated by HMRC-recognised exchanges (Nasdaq Riga, Tallinn and Vilnius). They are not registered SME Growth Markets under MiFID II, and have lighter rulebooks than the Nordic First North markets. For ISAs, admission on a market of an RSE could in principle qualify, but the lighter regime creates a grey area. Conservative treatment: mark as unclear unless HMRC explicitly includes/excludes.

• HMRC “shorter tables” — Baltics: main markets “Listed”; First North “Not listed” (listing test only).
  HMRC — recognised exchanges (shorter tables)
• Nasdaq Baltic rulebooks:
  Nasdaq Baltic — First North overview
• HMRC — Recognised Growth Markets list (includes Vienna MTF & Nasdaq Baltics):
  STSM041330 — Recognised Growth Markets
• ISA admission test (post-2013):
  HMRC ISA manager guidance

Working stance: Operated by RSEs, but absent SME GM registration and with minimal obligations, classification as “Eligible Post 2013” is possible yet uncertain.

Summary: These tiers are unofficial markets, not MiFID RMs or MTFs. The ISA admission test requires admission to trading on a market of a recognised exchange in the MiFID sense, so these tiers fail despite being run by an RSE. Note: Frankfurt’s Scale segment sits within Open Market but has enhanced obligations. See the separate “Scale” modal for the Post-2013 argument.

• HMRC Germany page: separates Regulierter Markt (qualifies) vs Freiverkehr/Open (not qualifying).
  HMRC “shorter tables” — Germany
• ISA admission requirement:
  HMRC ISA manager guidance

Bottom line: Not MiFID RM/MTF ⇒ not a qualifying “market of the RSE” for ISAs. Scale is discussed separately as a potential exception on Post-2013 logic.

Summary: Scale is a curated segment within Frankfurt’s Open Market featuring designated sponsors, enhanced admission, research/coverage, and continuing disclosure obligations. While the broader Open Market is non-qualifying, Scale more closely resembles junior markets that UK industry has treated as ISA-eligible post-2013 (e.g., AIM, Euronext Growth, certain First North venues) because those are markets of an HMRC-recognised exchange with defined rulebooks and surveillance.

Why there is an arguable route:

• The ISA rule looks to admission to trading on a market of an HMRC-recognised exchange. It does not expressly require RM/MTF status in the statutory wording.
• Scale operates under the exchange’s auspices with a formal admission process, sponsor regime, and ongoing obligations — i.e., a genuine market framework rather than a purely informal quote board.
• Analogy: UK acceptance of junior, exchange-operated markets (AIM; Euronext Growth) under the Post-2013 logic because they are true markets of an RSE with codified rules.

Counterpoints / risks:

• Scale is not a MiFID RM or MTF; HMRC’s Germany table groups it under Open/“Not listed”.
• HMRC has not explicitly stated that Scale qualifies; nor is it on HMRC’s Recognised Growth Markets list.
• Therefore inclusion would be an interpretation risk. Oppl will pressume non-qualifying for safety

• HMRC — Germany (context): distinction of Regulierter Markt vs Open/Freiverkehr.
  HMRC “shorter tables” — Germany
• ISA manager guidance (admission test):
  HMRC ISA manager guidance

Bottom line: Treat Scale with caution. Oppl will pressume non-qualifying for safety.

Summary: Euro MTF is an MTF operated by an HMRC-recognised exchange (LuxSE). Post-2013 ISA rules allow eligibility via admission to trading on a market of the RSE.

• LuxSE Euro MTF:
  LuxSE — Introducing Euro MTF
• HMRC recognition (Luxembourg):
  HMRC “shorter tables” — Luxembourg
• ISA admission rule:
  HMRC ISA manager guidance

Practice point: Common for debt; equities possible but rarer — document admission evidence.

Summary: Like other Euronext Growth markets, the Oslo venue is an MTF operated by an HMRC-recognised exchange and (per Euronext) follows harmonised Growth principles. Under the 2013 ISA admission logic, securities admitted here can qualify.

• Euronext Growth Oslo (overview):
  Euronext Growth Oslo
• Euronext — SME Growth Market status (group context):
  Euronext — SME Growth Market status
• HMRC country page (Norway): main market listed; smaller markets “Not listed” (listing test); ISA test differs.
  HMRC — Norway
• ISA rule: admitted to trading on a market of an HMRC-recognised exchange.
  HMRC ISA manager guidance

Summary: HMRC’s Recognised Growth Market list (STSM041330) includes Vienna MTF (Wiener Börse). While the HMRC country table shows “Not listed” for the listing test, the ISA admission test (post-2013) can be met for securities admitted to trading on this market of an RSE.

• HMRC — Recognised Growth Markets list:
  STSM041330 — Recognised Growth Markets
• HMRC Austria (context):
  HMRC “shorter tables” — Austria
• ISA guidance (admission test):
  HMRC ISA manager guidance

Practice: Treat Vienna MTF as within scope under the post-2013 admission test, documenting the Recognised Growth Market reference.

Summary: Although NewConnect is operated by the Warsaw Stock Exchange — which is recognised by HMRC — the NewConnect segment itself is a local junior market designed for early-stage companies and authorised as an MTF, not as a Regulated Market or SME Growth Market. HMRC’s Poland page shows NewConnect as “Not listed”, reflecting that it does not meet the formal listing criteria under ITA 2007 s1005(3). For ISA purposes, while some MTFs operated by RSEs (such as AIM or Euronext Growth) may qualify under the post-2013 “admitted to trading” rule, NewConnect’s much lighter disclosure and admission regime means it is not generally treated as a qualifying market of the RSE.

Why it differs from SME Growth Markets:

• No MiFID II “SME Growth Market” registration: NewConnect is an MTF but not classified as an SME GM, which means it does not benefit from the harmonised investor-protection and disclosure framework that Euronext Growth or First North markets do.
• Reduced admission and reporting standards: Companies can list without a prospectus, and ongoing obligations are lighter than those expected of “functional” exchanges under HMRC’s criteria.
• Local market scope: NewConnect primarily serves domestic Polish issuers and retail investors, with very limited cross-border oversight or harmonisation compared with EEA SME GMs.
• HMRC’s functional test: Even though operated by an RSE, HMRC expects qualifying markets to show robust regulatory oversight, reporting obligations, and investor protections — features that NewConnect lacks in practice.

• HMRC — Poland:
  HMRC “shorter tables” — Poland
• WSE — NewConnect overview:
  WSE — NewConnect
• MiFID II SME Growth Market comparison:
  ESMA Register — SME Growth Markets
• ISA guidance (admission test):
  HMRC ISA manager guidance

Conclusion: Although operated by a recognised exchange, NewConnect does not meet HMRC’s functional or regulatory expectations for a qualifying market. Unless HMRC explicitly recognises it or the market attains SME Growth Market status, NewConnect should be treated as ineligible for ISA purposes.

Summary: HMRC indicated (in correspondence you shared) that where an MTF exists as a separate exchange/venue rather than a market of a designated RSE, it would need to apply for RSE designation. BME Growth is not designated as an RSE; hence ineligible.

• HMRC recognition principle (per email): Independent MTFs must apply for RSE status individually.
• HMRC Spain page (context for RSEs):
  HMRC “shorter tables” — Spain
• ISA admission requirement:
  HMRC ISA manager guidance

Contrast: Latibex is operated under Madrid’s RM licence; BME Growth is a separate venue.

Summary: Operated by HMRC-recognised Euronext exchange entities; SME GM registration; harmonised rulebooks. Meets the ISA admission test as a market of an RSE.

• Euronext — SME Growth Market status
• HMRC ISA manager guidance