Employment Related Securities (ERS): Don’t miss your annual reporting deadline

If your business operates any form of employee share scheme – or has awarded shares or share options to employees or directors during the tax year ending 5 April 2026 – you may have important reporting obligations with HMRC.

Each year, companies must file an Employment Related Securities (ERS) return to report share issues, share option activity, or any other employment related securities events involving employees, directors, or their family members.

The deadline for submitting yourEmployment Related Securities (ERS) return for the 2025/26 tax year is 6 July 2026.

When you need to file an ERS return

You are likely to have a reporting requirement if any of the following apply during the tax year to 5 April 2026:

• Shares were issued to employees, directors, or their family members
• Share options were granted to employees, directors, or their family members
• A new share scheme was set up or an existing scheme continued during the year
• A one-off transaction took place, such as an employee or director acquiring shares because of their employment

If any of these events occurred, you must register the scheme online and file a return with HMRC.

This applies to all types of plans, including:

• Enterprise Management Incentives (EMI)
• Company Share Option Plans (CSOP)
• Save As You Earn (SAYE) schemes
• Share Incentive Plans (SIP)
• Any non-tax advantaged share arrangements

No transactions? You still need to file

Even if no reportable activity has taken place during the year, you must still submit a nil return for any scheme registered on HMRC’s system.

A return is required every year until the scheme is formally closed online. Failing to file – even where nothing happened – will trigger penalties.

Penalties for late or incorrect filing

HMRC imposes penalties for:

• Late submission of an ERS return
• Incorrect or incomplete information

It’s essential that returns are prepared carefully and submitted on time to avoid unnecessary charges.

EMI notifications: Important deadline changes

For EMI options granted on or after 6 April 2024, the deadline for notifying HMRC is now 6 July following the end of the tax year.

This means:

• EMI options granted in the tax year ending 5 April 2026 must be notified by 6 July 2026
• EMI options granted in the tax year ending 5 April 2027 must be notified by 6 July 2027

From 6 April 2027, the Government plans to remove the standalone EMI notification requirement entirely. At that point, EMI reporting is expected to be aligned with CSOP – with all activity captured through the annual end of year ERS return.

We’re here to help

Understanding your reporting obligations – and ensuring everything is filed correctly – can be complex, especially if multiple schemes or historic arrangements are involved.

Our share schemes and employment tax specialists can support you with:

• Determining whether you need to register and report
• Completing and filing ERS and EMI submissions
• Managing scheme compliance throughout the year
• Advising on the governance and effectiveness of employee share plans

If you operate an employee share scheme or think you may have a reporting requirement, get in touch with our team for clear, practical support ahead of the 6 July deadline.