What the LSE's worst-case analysis actually says

The internal analysis, first reported by The Sunday Times, identifies 20 FTSE 100 companies whose existing American Depositary Receipt programmes on US exchanges could be converted into direct ordinary-share listings in New York, mirroring the path taken by AstraZeneca last year.

The companies flagged include HSBC (LSE: HSBA), currently the exchange's largest constituent by market capitalisation; oil majors BP (LSE: BP.) and Shell (LSE: SHEL); telecoms groups BT (LSE: BT.A) and Vodafone (LSE: VOD); drinks group Diageo (LSE: DGE); and publishers Pearson (LSE: PSON) and RELX (LSE: REL).

The scenario is explicitly labelled worst-case. Not every company on the list has signalled an intention to move. But the LSE's willingness to model the outcome at all reflects how sharply sentiment has shifted since AstraZeneca announced its NYSE direct listing in September 2025, citing the need for "the flexibility to access the broadest possible available pool of capital," according to the City AM report.

AstraZeneca's direct listing replaced its previous Nasdaq ADR programme and became effective in February 2026. The Cambridge-headquartered group, valued at approximately £200bn, remains a FTSE 100 member. Yet its share trading in London is no longer liable for stamp duty, a distinction that matters both to the Treasury's revenue line and to the signalling effect on other dual-listed companies.

The stamp duty arithmetic: £2bn at stake

London levies a 0.5 per cent stamp duty charge on every share purchase. The LSE's analysis estimates that if all 20 companies in its scenario followed AstraZeneca's lead, the cumulative loss to the Exchequer would reach £2bn, according to The Sunday Times report.

AstraZeneca's move alone is estimated to have cost the Treasury roughly £200m in forgone stamp duty, according to City AM. Scaling that figure across a broader cohort of large-cap issuers with significant US trading volumes produces the headline number.

Charles Hall, head of investment at Peel Hunt, has warned there is "a clear risk" to stamp duty earnings "if more of our largest companies follow AstraZeneca's lead in harmonising their listing," according to Peel Hunt analysis cited by City AM. The investment bank argues that removing the levy would reduce the financial incentive for companies to consider relocation in the first place.

Separately, a February 2026 poll by investment platform Interactive Investor found that 75 per cent of investors said abolishing stamp duty on UK shares and investment trusts would encourage them to invest more in domestic equities, according to the platform's published findings.

What a blue-chip exodus means for smaller listed firms

The direct fiscal cost is only part of the picture. For boards of mid-cap and growth-stage companies listed, or considering listing, in London, the more pressing question is what happens to the capital-markets ecosystem if its anchor tenants leave.

Blue-chip stocks generate the bulk of daily turnover on the London Stock Exchange. They attract the global fund managers, prime brokers, and sell-side analysts whose presence sustains a functioning market infrastructure. When a large issuer shifts its primary trading venue to New York, a portion of that institutional attention follows.

Liquidity and index weight

Each departure reduces the aggregate free-float market capitalisation of the FTSE indices. Passive funds tracking those indices reallocate accordingly. Active managers benchmarked against the FTSE 100 or FTSE All-Share have fewer large, liquid names to trade in London, which can widen bid-offer spreads across the board.

For a FTSE 250 or AIM-listed company seeking to raise equity, the depth of the local investor base matters. A thinner pool of London-engaged institutional capital means more competition for fewer allocation decisions, potentially raising the cost of equity for domestically focused firms that have no realistic option of listing in New York.

Analyst coverage and visibility

Sell-side research coverage in London has already contracted over the past decade. If the largest revenue-generating clients move their listings offshore, brokerages face further pressure to cut UK equity research teams. That coverage gap tends to hit smaller companies hardest; large firms can attract analyst attention regardless of listing venue, while mid-caps rely on a functioning local research ecosystem for visibility with fund managers.

The FCA's 2024 listing-rule overhaul was designed to make London more competitive by simplifying the listing categories and easing eligibility requirements. AstraZeneca's subsequent move suggested that regulatory reform alone may not be sufficient to retain the largest issuers, particularly when the economic incentive of avoiding stamp duty is layered on top of deeper US capital-market liquidity.

Policy options: scrap the levy or risk the flight

The policy debate now centres on whether the stamp duty itself has become a structural disadvantage that no amount of regulatory modernisation can offset.

Peel Hunt's analysis makes the case that abolition would remove the single clearest financial incentive for companies to relocate trading to a jurisdiction that does not levy an equivalent charge. The United States has not imposed a transaction tax on share purchases since 1966.

The counterargument is fiscal. Stamp duty on shares raised approximately £3.8bn for the Treasury in the 2023-24 tax year, according to HMRC data. Scrapping it entirely would require either replacement revenue or spending cuts, neither of which is straightforward in the current fiscal environment.

"There is a clear risk to the earnings from stamp duty if more of our largest companies follow AstraZeneca's lead in harmonising their listing," Charles Hall of Peel Hunt said, as reported by City AM.

A middle path, floated by some market participants, would be to cut the rate rather than eliminate it, narrowing the cost differential with New York without surrendering the full revenue stream. Whether that would be enough to change behaviour for companies already weighing the deeper liquidity and higher valuations available on US exchanges is an open question.

AstraZeneca itself has not severed its UK ties. In April 2026, the company announced plans to invest £300m in its UK operations, including reviving a £200m commitment to a Cambridge laboratory complex and injecting a further £100m into its Macclesfield site, according to City AM. The investment came only months after a public dispute with the UK government over drug pricing.

That combination, a direct NYSE listing alongside continued UK capital expenditure, may prove to be the template other multinationals follow. For London's capital markets, the risk is that "harmonised" listings become the norm for the largest constituents, gradually shifting primary trading volumes westward while the companies themselves maintain a nominal London presence.

For mid-cap and scale-up boards, the practical implication is less abstract. A London market increasingly populated by domestically focused firms, with fewer global giants anchoring index flows, is a market where raising equity becomes harder and more expensive. The stamp duty debate is, at its core, a debate about whether London can remain a viable venue for growth capital.