The deadline for HMRC’s annual share plan reporting for the 2025/26 tax year is approaching quickly.
Any of your clients with UK employees participating in share plans, including UK businesses, US-parented groups and multinational organisations, will need to ensure they meet their Employment Related Securities (ERS) reporting requirements to avoid penalties and maintain tax advantages.
This guide outlines the key requirements for 2026 and highlights where advisers can support clients in managing their reporting obligations effectively.
At a glance: UK share plan reporting requirements
• Ensure all new share plans or arrangements are registered with HMRC
• File an annual ERS return for each registered arrangement
• Submit nil returns where there has been no reportable activity
• Confirm that any tax-advantaged plans have been properly self-certified
What is the deadline for UK share plan reporting in 2026?
The filing deadline for ERS annual returns for the 2025/26 tax year is:
• Midnight (UK time), 6 July 2026
• All submissions must be made through HMRC’s online ERS system
Clients who have not yet registered should do so by 22 June 2026 at the latest to allow sufficient time for access to be set up.
Which clients are required to file ERS returns?
Any client that has operated share plans or facilitated share-related transactions involving UK employees or directors will have an annual obligation to:
• Register new reportable arrangements
• Submit ERS returns for each scheme
• Report all relevant ERS events
This applies to clients with:
• Share options or equity awards involving UK individuals
• Securities connected to UK employment duties
• Global share plans with UK participants
Including:
• UK-based companies
• Overseas groups issuing equity to UK employees
• Organisations with internationally mobile employees performing duties in the UK
You may wish to alert your clients to this deadline. You are welcome to adapt the content below to share with your clients. You can also view our article notifying corporate businesses of this deadline here.
Example communication you can send to clients:
Dear [Client Name],
We are approaching the HMRC deadline for annual share plan (ERS) reporting for the 2025/26 tax year (6 July 2026).
If your business operates share plans or has issued equity to UK employees or directors, you may be required to:
- Register any new share plan arrangements
- Submit annual ERS returns
- File nil returns where no activity has occurred
We recommend reviewing your position now to avoid penalties and ensure compliance.
If you would like support with your ERS reporting or a quick review of your current arrangements, please let us know.
What events should be reported to HMRC?
Your clients must report any notifiable ERS activity during the tax year. This typically includes:
• Granting rights to acquire shares or securities
• Employees acquiring shares or securities
• The removal of restrictions (e.g. vesting or forfeiture conditions)
New share plan registrations
A new ERS registration will be required where:
• A client introduces a new share plan
• A transaction creates a new equity structure
• Existing registrations do not cover the awards being made
Once completed, HMRC will issue a scheme reference number, which is required for all future filings.
As HMRC can take up to 10 days to process registrations, advisers should encourage clients to act well in advance of reporting deadlines.
It is also important to note that agents cannot complete registrations on behalf of clients, although they can support the process.
Failure to register and self-certify correctly may result in the loss of tax advantages for relevant plans.
Do your clients need to self-certify share plans?
Yes, where tax-advantaged plans are in place, including:
• Share Incentive Plans (SIP)
• Save As You Earn (SAYE) schemes
• Company Share Option Plans (CSOP)
Clients must confirm that these plans meet the relevant statutory requirements at the point of implementation or first award.
Common share plan reporting errors to flag to clients
• Excluding internationally mobile employees
Employees working partly in the UK must still be included in reporting.
• Omitting non-executive directors
These individuals must be included under the correct reporting category.
• Incorrect or duplicate scheme registration
Registering a scheme twice is a frequent issue and can lead to confusion and penalties.
• Missing deadlines or failing to submit nil returns
Clients must file even where there has been no activity during 2025/26.
Remember: the reporting deadline is 6 July 2026.
• Incorrectly closing schemes
Only the company (not the agent) can formally cease a scheme via HMRC’s system.
• Template errors when uploading returns
Altering HMRC templates (e.g. deleting columns) can cause submission failures.
Are there penalties for late filing?
Late or missed filings can result in escalating penalties:
• £100 initial penalty per return
• £300 additional penalty after 3 months
• £300 additional penalty after 6 months
• £10 daily penalties after 9 months
In addition to financial penalties, clients risk losing the tax-advantaged status of their share plans.
How can you support your clients?
Advisers play a key role in helping clients navigate ERS compliance. Support may include:
- Identifying reportable events and obligations
- Assisting with plan registration and self-certification
- Reviewing reporting processes and data accuracy
- Managing submissions and deadlines
- Advising on cross-border share plan complexities
- Ensuring compliance with data protection requirements
Providing proactive guidance ahead of the July deadline can significantly reduce risk for clients and improve reporting outcomes.
Get ahead of the deadline
If your clients operate UK share plans, now is the time to ensure their reporting processes are accurate, complete and compliant.
Early preparation will help avoid last-minute issues and minimise the risk of penalties.
