CLLS Company Law Committee's response to Chapter 7 (Notifying purchases of own securities under UKLR) of FCA Quarterly Consultation Paper CP25/24. 

The CLLS notes that the disclosure obligations under the UKLRs and the MAR regime are currently non-aligned resulting in overly onerous administrative obligations.
Amending the UKLRs in the proposed manner would streamline the FCA Handbook and provide issuers with the flexibility to aggregate post-trade buy-back disclosures into a single weekly notification. 

Additionally, the CLLS would ask the FCA to consider further simplification of the post-trade reporting requirements such that the issuer only has to disclose to the public aggregated trade information rather than trade-by-trade data. Such a reduction in the compliance burden took effect for EU share buybacks, from 4 December 2024, under EU Listing Act changes.