ISA Eligibility — HMRC Positions on MTFs & “Admitted to Trading”
Summary aligned with our EEA segments table. Focus: how HMRC treats multilateral trading facilities (MTFs), the role of recognised stock exchanges (RSEs), and the post-2013 ISA “admitted to trading” test.
Key takeaways (at a glance)
No blanket ban on MTFs“Admitted to trading” ≠ “listed”Markets of an RSE can qualifyRecognised Growth Markets help (signal)Independent MTFs may need RSE designation“Functions like an exchange” matters
ISAs (post-2013): Shares can be eligible if they are admitted to trading on a market of a recognised stock exchange in the UK or the EEA — they do not also have to be “listed”.
MTFs: There is no blanket ban. If an MTF is genuinely a market of a designated RSE (e.g., AIM of LSE; Euronext Growth of the local Euronext exchange), the ISA admission test can be met.
Independent MTFs: Where an MTF is a separate venue and not a market of a designated RSE (e.g., BME Growth), HMRC expects it to apply for RSE designation before its securities could qualify via the “market of an RSE” limb.
“Listed” vs ISA: HMRC’s country tables use “listed/not listed” for the listing definition in ITA 2007 s1005(3). ISA eligibility uses the broader admitted to trading test, so “not listed” does not automatically mean “not ISA-eligible”.
Recognised Growth Markets (RGM): HMRC’s RGM list (for stamp taxes) includes Vienna MTF and the Nasdaq Baltics First North platforms. RGM status is not the ISA test, but it’s a useful quality/oversight signal that supports a post-2013 rationale when the market is a genuine segment of an HMRC-recognised exchange.
Practical test: (1) the operator is an HMRC-recognised exchange, (2) the venue is truly a market of that exchange (or is itself designated), and (3) the securities are admitted to trading on that market.
HMRC clarifications (email to Oppl, 15 Oct 2025 — paraphrased)
Two HMRC lists exist and work slightly differently: (i) a list that names specific exchanges designated as RSEs; and (ii) a list that designates whole jurisdictions. In both cases, all markets of those exchanges form part of the RSE unless HMRC expressly excludes a market.
Carve-outs are explicit: HMRC’s example on the tables: “The First North market of NASDAQ OMX Tallinn has not been included in this recognised stock exchange designation.” If HMRC intends an exclusion, it says so.
“Not listed” ≠ “not an RSE market”: The “listed/not listed” flag in country tables is about the listing definition in ITA 2007 s1005(3). A market marked “not listed” can still meet rules that require admission to trading on a market of an RSE.
Post-2013 ISA limb: The ISA rules can be satisfied by securities that are listed on an RSE or admitted to trading on any market of an EEA RSE (subject to the other ISA criteria being met).
Tables can lag the real world: HMRC relies on exchanges to report changes and notes that names/operations may not always be perfectly current; what matters is the fact pattern (operator, market status, admission) and any explicit HMRC carve-outs.
How we use this: In grey areas, we confirm the operator/venue relationship, assess whether the market functions like an exchange (admissions, continuing obligations, disclosures, oversight), and check for HMRC carve-outs. Absent an explicit exclusion, being a market of an RSE supports the ISA “admitted to trading” limb.
HMRC Statements to Oppl (direct quotes)
Emails dated 13 Oct 2023
“we do not see any reason why an MTF could not be designated as a recognised stock exchange.”
“there is no blanket ban on MTFs qualifying providing they satisfy our standard criteria.”
“To date, the only MTFs which have RSE status are those which are operated by traditional stock exchanges… where the stock exchange as whole has been designated, including the MTF segment.”
“the BME Growth Market… exists a separate, independent market. In which case the starting point would be for the BME GM to apply for RSE designation itself.”
“For ISAs… They do not have to be ‘listed’ in order to qualify, if traded on RSE markets in the UK or the EEA.”
Emails dated 15 Oct 2025
“RSE status… is determined by legal designation… Any market operated by that stock exchange will form part of the RSE as matter of legal designation, unless specified otherwise…”
“To put it another way, ‘not listed’ does not mean ‘not designated as an RSE’… Typically a security traded on a ‘not listed’ market will satisfy a requirement along the lines of ‘traded/admitted to trading’ on an RSE…”
“Since 2013 securities can meet the RSE part of the ISA test by either (a) being listed on an RSE, or (b) being admitted to trading on any market of an RSE in the EEA.”
“We endeavour to keep the tables up-to-date… it does list all designations HMRC has made… While we also provide some guidance on the listed/not listed status of markets, ultimately this remains a question of fact for taxpayers and their advisers.”
How to read our table (and the common grey areas)
Euronext Growth (Paris/Amsterdam/Brussels/Dublin/Lisbon) Eligible Post 2013: Operated by the local Euronext RSE entity with harmonised rulebooks; Euronext confirms SME Growth Market status. ISA admission is satisfied via “market of an RSE”. Euronext — SME Growth Market status
Euronext Access Ineligible: Entry-level Access/Access+ tiers have light-touch admissions and minimal ongoing disclosure. HMRC expects qualifying markets to function like a stock exchange with meaningful reporting, investor protections and oversight. On that functional basis, we treat Access as not qualifying for ISAs (whereas Euronext Growth meets those expectations). AMF lists Access as an MTF, but label alone doesn’t satisfy the ISA test without the functional standards above.
Vienna MTF (Direct Market/+) Eligible Post 2013: Listed by HMRC as a Recognised Growth Market. Combined with the operator being an RSE, this supports ISA inclusion via admission to trading on a market of an RSE. HMRC STSM041330 — RGM list
Nasdaq First North (Nordics) Eligible Post 2013: Operated by recognised Nasdaq exchanges; many segments are SME Growth Markets. Matches the post-2013 “admitted to trading” logic. Several UK platforms accept First North in ISAs, which supports market practice.
Nasdaq First North (Baltics) Possibly Eligible Post 2013 / Unclear: Appears on HMRC’s RGM list (positive signal), but these venues are not MiFID II SME GMs and operate with lighter regimes than Nordic First North. HMRC correspondence (15 Oct 2025) shows HMRC will explicitly carve out a market when intended (e.g., First North Tallinn). Given the lighter framework and absent explicit ISA confirmation, we treat Baltic First North as unclear and, for client safety, ineligible by policy unless further HMRC guidance emerges. HMRC STSM041330 — RGM list
Germany — Regulierter Markt Eligible: MiFID Regulated Market segments (Prime/General) meet both the “listed” and ISA admission tests.
Germany — Open/Freiverkehr/Quotation Board Ineligible: Exchange-regulated/unofficial tiers that are not MiFID RM/MTF. HMRC’s email (15 Oct 2025) clarifies “not listed” markets can still be RSE markets; however, these tiers do not meet the functional standards we require for ISA inclusion. Excluded by policy unless HMRC gives explicit comfort.
Germany — Frankfurt “Scale” Possibly Eligible Post 2013 (unclear): A curated Open Market segment with enhanced admission/sponsor/continuing obligations. Still not RM/MTF and grouped under “not listed” in HMRC’s country table. You can articulate a post-2013 analogy, but absent HMRC comfort we treat as ineligible by policy.
Spain — BME Growth Ineligible: Separate, independent venue. HMRC’s position (13 Oct 2023 & 15 Oct 2025 emails) is that independent MTFs should apply for RSE designation in their own right; otherwise they do not meet the “market of an RSE” limb.
Country tables tip: If a venue shows as “not listed” in HMRC’s country tables, that label is for the listing test (ITA 2007 s1005). For ISAs, focus on: the operator is an RSE; the venue is its market; the security is admitted to trading on that market. Where HMRC gives an explicit exclusion, that overrides general logic.