Consultation on the framework for a UK equity consolidated tape

We appreciate the opportunity to respond to the Financial Conduct Authority’s consultation paper CP25/31 on the framework for a UK Equity consolidated tape. Our response is based on our experience as an active participant in UK markets.

NBIM is the investment management division of the Norwegian Central Bank (“Norges Bank”) and is responsible for investing the Norwegian Government Pension Fund Global in a globally diversified manner. NBIM held assets valued at NOK 21 286 billion as of 31 December 2025, of which GBP 86 billion was in UK equities and bonds of UK issuers.

As a long-term investor NBIM has an interest in well-functioning financial markets that facilitate the efficient allocation of capital and promote long-term economic growth, and thus in a regulatory environment for trading in financial instruments that facilitates such an outcome. This means that we engage in market structure developments that affect market liquidity, transparency, and execution quality.

On the equity tape 

NBIM supports the FCA's proposal to establish a consolidated tape including both post-trade data and the attributed pre-trade best bid and offer (BBO). Pre-trade transparency reduces information asymmetries between market participants, narrows bid-ask spreads and improves price discovery. In a market with venue competition, a consolidated tape can serve as an important coordinating mechanism. For institutional investors, access to the best bid and offer across all UK venues facilitates best execution evaluation and transaction cost analysis. This enables us to improve our trading strategies.

Large Investment firms have access to direct exchange feeds with very low latency and full depth of book, which offer more current information compared to a consolidated tape. These superior feeds will remain differentiated products. Further enhancement to the depth of the consolidated tape or the speed of delivery are beneficial, but only if such enhancements can be provided at reasonable cost given available technology.

We find that the regulatory approach of establishing comprehensive data and latency requirements for a consolidated tape and no compulsory consumption of data, while addressing efficacy through competitive procurement of a consolidated tape provider, and relying on existing best execution obligations is well balanced. However, we believe the provision of a consolidated tape have clear natural monopoly characteristics, and the efficacy of re-tendering provisions may prove illusionary. This means robustly designed governance mechanisms should be implemented at the outset.
 
NBIM view the consolidated tape as a critical utility in market infrastructure and an important contribution to the competitiveness of UK markets. Successful delivery will strengthen UK market structure and provide material benefits to market participants by enabling a more informed assessment of available liquidity.

We would underscore that even though a UK equity consolidated tape is useful as a standalone source, its value would be much enhanced in a broader European context. Regulatory requirements should not hinder a potential future market-driven integration of the UK and EU consolidated tapes.      

Our detailed response to the consultation questionnaire can be found in the appendix. We thank you for considering our perspective and remain at your disposal should you wish to discuss these matters further.

Yours sincerely,

Emil Framnes
Global Head of Equity Trading and Transition                                                            

Vegard Vik
Special Advisor