°Ç¸ç³Ô¹Ï

Enterprise Management Incentives (EMI) changes to the scheme thresholds from April 2026

An increase to EMI thresholds was announced at Budget 2025 and is being introduced from 6 April 2026.

EMIÌý²õ³¦³ó±ð³¾±ðs are targeted share option schemes designed to support enterprises in recruiting and retaining key employees.ÌýCompanies can choose:

• which eligible employees receive options
• how many share options each selected employee receives
• the exercise price and vesting conditions

EMIÌýthreshold change

The government has introduced legislation in the Finance Bill 2025-26 to expandÌýEMIÌý²õ³¦³ó±ð³¾±ð limits from 6 April 2026 to allow more companies to use the scheme.

From 6 April 2026, the EMI limits will be increased for most companies as follows:

• the maximum value of company options (from £3 million to £6 million)
• the value of gross assets (from £30 million or less to £120 million or less)
• the number of employees (from fewer than 250 to fewer than 500)
• the maximum holding period (from 10 years to 15 years)

Where the employer company is a specified company, the limits increase, and extended exercise period will not apply. A specified company is a company with its registered office in Northern Ireland which trades in goods or the provision of electricity. Further guidance on specified companies will be published in the Employee Tax Advantaged Share Scheme User Manual (ETASSUM) ahead of 6 April 2026.

For the first year, there will be no change to the current EMI reporting requirements.

For options granted on or before 5 April 2026 the original scheme limits will apply.

However, the extension of the holding period can be applied retrospectively to existing contracts that have not expired or been exercised — the tax advantages will be retained provided that these contracts are amended in line with the option agreement or legislation (where required).

There will be no change to the EMI reporting requirements relating to the maximum holding period.

Employment Related Securities (ERS) reporting requirements for short term business visitors (STBV)

Where an employee is a short term business visitor who is covered by an EP Appendix 4 arrangement, HMRC will no longer require companies to report non-tax advantaged ERS data for these employees, provided no UK Income Tax and National Insurance contributions would be due.

This applies for all previous and future tax years. The ERS reporting obligation remains in rare scenarios where UK Income Tax and National Insurance contributions would be due, such as where the STBV was previously a UK resident and share options were granted at that time.

The Employment Related Securities Manual (ERSM140030) has been updated to reflect this.Ìý

Further information and guidance will be provided in due course.

End of year filing reminder

If youÌýoperateÌýan employee share scheme you must file an end of year ERS °ù±ð³Ù³Ü°ù²Ô.Ìý

For the 2025Ìýto 2026 tax year,Ìýyou mustÌýsubmitÌýan end of year ERS return (on or before) 6 July 2026. If you miss this deadline, you will receive a late filing penalty.Ìý

You mustÌýsubmitÌýa return or nil return for every scheme that you have registered on the ERS online service.Ìý

You must make sure you are submitting the correct end of year return template for the scheme you are operating. You must also make sure that you are using the most up to date version, or the ERS online service will reject your submission.

You should cease the scheme If you have:

• registered a scheme in error
• a scheme which is no longerÌýoperating

You must stillÌýsubmitÌýan annual return for ceased schemes for the tax year in which the final event date falls.Ìý

If you’ve stopped being an employer and have ceased your Pay as You Earn (PAYE) scheme, you’ll also need to consider whether you need to cease yourÌýERSÌý²õ³¦³ó±ð³¾±ð.

Read about how toÌýsubmitÌýan ERS return orÌýsubmitÌýa nil return.

EMI notifications

If you operate an EMI scheme and you have granted options on or after 6 April 2024, you must submit your EMI notifications by 6 July following the end of the tax year. Therefore, for options granted during the 2025 to 2026 tax year, the EMI notification must be submitted by 6 July 2026.

You must also submit an end of year return for all live EMI schemes by 6 July 2026.

The government announced at Budget 2025 that it will legislate to remove the EMI notification for options granted on or after 6 April 2027. An EMI notification is still required for options granted before 6 April 2027.

Saving copies of your returnÌýand notifications

Before youÌýsubmitÌýyourÌýERSÌýreturn orÌýEMIÌýnotification, you must save a copy of it for your own records.Ìý

If you are uploading an EMIÌýnotification attachment,Ìýyou must save a copy of the file. If you are filling in the details online, you may want to take screenshots of each page and save themÌýalong with the confirmation page.Ìý

You will not be able to access a copy of what youÌýsubmitÌýthrough theÌýonline serviceÌýonce you haveÌýsubmittedÌýit.

Penalties for late filing

A £100 penalty will be issued automatically if the end of year ERS return, including nil returns whereÌýappropriate, is notÌýsubmittedÌýby 6 July 2026.Ìý

AdditionalÌýautomatic penalties of £300 will be charged if the return is still outstanding 3 months after the original deadline of 6 July, and a further £300 ifÌýit’sÌýstill outstanding 6 months after that date.Ìý

Even if you have received and paid theÌýinitialÌýpenalty, you must stillÌýsubmitÌýan end of year or nil return to meet your filing obligations and prevent further penalties.

ERS administrators

Every year many customers fail to meet the ERS filing deadline because they discover that they cannot log in.ÌýThis is often because the only person who could log in to file the return has left the company or is away.Ìý

ÌýIt is best to have more than one administrator for your Government Gateway account in case the primary administrator is unavailable. The backup administrator can manage accounts and perform various functions, including:

• adding new users
• managing access levels
• submitting ERS returns

Having a backup administrator makes sure that critical functions can still be carried out, even if the main administrator is unable to access the system.

Read about how to set up a backup administrator (a team member) using your business tax account.

End of year template guidance updates for April 2026

Bulletin 62 (November 2025) provided information on Private Intermittent Securities and Capital Exchange SystemÌý(PISCES) announced at Budget 2025.

Bulletin 63 (January 2026)Ìýprovided an update on net settlement reporting.

Following these bulletins, relevant questions within the end of year template guidance notes have now been updated.

Modernising and mandating tax advisor registration

Read about the newÌýlegalÌýregistration requirement for tax advisers who interact with HMRC in relation to their clients’ tax affairs.Ìý

The guidance explains:

• whoÌýis required toÌýregister
• when registration must take place
• what information advisers will need to provide as part of the process

Tax advisers who register will also need to meet HMRC’s registration conditions, which are set out in the linked guidance.Ìý

This will help protect taxpayers fromÌýtaxÌýadvisers whoÌýaren’tÌýfit to act and supports a fairer market for compliant taxpayers and advisers.Ìý

HMRC willÌýpublish furtherÌýcommunications andÌýguidanceÌýahead of May 2026.

What will change from May 2026

FromÌý18ÌýMay 2026, tax advisersÌýwho interact with HMRC on behalf of their clients willÌýbe requiredÌýto register with HMRC. They willÌýneed to do soÌýthroughÌýHMRC’s agentÌýservices accountÌý(ASA).Ìý

Changes are being made to the servicesÌýto simplify the current registration process and reduce the administrative burden on tax advisers.ÌýAs part of the process, HMRC will automate some of the checks it will place on tax advisers — changes which will be completed by April 2027.Ìý

Once an application has been approved,Ìýthe businessÌýwill be issued with anÌýagent reference number, which will give them accessÌýto key services, including:

• Self Assessment
• Corporation Tax
• PAYE for employers (including the Construction Industry Scheme (CIS))

What this means for ERS agents

If youÌýdeal with HMRC on behalf of your clients’ tax affairs, you willÌýbe requiredÌýto register with HMRC.Ìý

When you need to registerÌýdepends on howÌýyou currently deal with HMRC.ÌýYou’ll need to register for an agent services account from 18 May 2026, unless either you already have: Ìý

• a Self Assessment or Corporation Tax account —Ìýyou’llÌýneed to register from 18 August 2026Ìý
• an agent services account — you’ll not need to register again — we’llÌýcontact you through your agent services account when we need more information from you, to check if you meet certain conditionsÌý

You can use the online service to register from 18 May 2026, even if you’reÌýnot required to do so until a later date.Ìý

You’llÌýhave 3 months from the date you need to register to apply for an agent services account. You can continue to interact with HMRC on behalf of your clients:Ìý

• on services thatÌýyouÌýalready useÌýduring these 3 months
• while HMRCÌýisÌýprocessingÌýyourÌýapplication

If youÌýseekÌýauthorisation to manageÌýERSÌý²õ³¦³ó±ð³¾±ðs on behalf of a company onceÌýyour 3 month periodÌýends, youÌýmust be registered beforeÌýyouÌýcan act.ÌýIf youÌýinteract with HMRC on ERS matters without being registered, youÌýmayÌýbe subject to sanctions, including suspension and fines.Ìý

Authorisation arrangements for ERS will otherwise remain unchanged.ÌýYouÌýwill continue to use the existing Online Agents Authorisation process, including the issue of authorisation codes sent by post to clients.

Accessibility improvements to ERS end of year templates from April 2027

To make sure that HMRC documentation is compliant with accessibility regulations, the ERS end of year return templates, guidance and technical notes are going through a review process with the aim to make them consistent, clear and user friendly.

HMRC plans to publish new versions of the end of year return templates, technical notes and guidance pages at the beginning of November 2026.ÌýThis will give employers 5 months’ notice to make any changes to non-standard HMRC templates used to submit ERS end of year returns.

Further information will be published in future bulletins.