Companies must file an annual return with HMRC reporting any share or share option activity involving UK employees and directors, and notify HMRC of any new EMI option grants, by 6th July following the end of the tax year. For the 2024/25 tax year recently ended, the deadline is Sunday 6th July 2025.
The annual return and any such grant notifications must be submitted online via the company's Government Gateway portal, following a one-time registration of the share scheme under the 'Employment-Related Securities (ERS)' area.
Annual return filing process
A return must be submitted for each share scheme registered with HMRC. The return templates for the latest tax year can be accessed here, and companies must select the correct return for each of their schemes. Non tax-advantaged share options/awards must be reported on the return template named "Other", and tax-advantaged EMI, CSOP, SAYE or SIP entitlements/events must be reported on the relevant scheme return.
Companies filing for the first time are advised to register their scheme well in advance of the deadline, as it can take several days for the registration to complete before the return can be submitted, and longer if access to PAYE Online Services needs to be obtained first. Only companies will be able to complete the registration step; agents cannot do so with agent access.
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