Employee Share Scheme reporting: What to complete by 6th July 2026

Employee share schemes continue to be a popular way for businesses to reward and retain talent, but they also bring annual reporting obligations that cannot be overlooked.

For any company operating share-based arrangements, 6th July 2026 is the key deadline for completing reporting requirements relating to the 2025/26 tax year. Missing this date can result in automatic penalties and increased compliance scrutiny.

What this applies to

Reporting obligations may arise where employees have:

• Been awarded shares in connection with their employment
• Been given the opportunity to purchase shares (including at a discount)
• Received share options to be exercised at a future date
• Participated in either formal incentive arrangements or informal share awards

These requirements apply whether or not the arrangement is tax-advantaged, including schemes such as Enterprise Management Incentive (EMI), as well as non-tax-advantaged plans.

All reporting is made to HM Revenue & Customs.

What employers need to do by 6th July 2026

To remain compliant for the 2025/26 tax year, employers should ensure the following actions are completed:

• Register any new share schemes: If a scheme was introduced during the 2025/26 tax year, it must be registered with HMRC within the required timeframe.
• Report relevant EMI activity: Any EMI options granted during the year must be notified, in addition to the annual return for the scheme.
• Submit an annual ERS return for each scheme: Every active scheme must be reported, even if there were no transactions during the year (a “nil return” is still required).
• Confirm ceased schemes where applicable: If a share scheme has ended, HMRC should be informed, with reporting still required for the final year of activity.

Why this matters

HMRC applies automatic penalties for late filing. These typically start at £100, with additional charges applied if delays continue beyond three and six months. Where multiple schemes are in place, these penalties can quickly escalate.

Beyond the financial impact, late or inaccurate reporting can also create administrative delays and additional queries from HMRC.

A few practical considerations can help avoid issues at filing stage:

• Ensure the correct, most up-to-date HMRC templates are used
• Keep internal records aligned with scheme activity throughout the year
• Retain a copy of each submission, as access to historical filings via HMRC systems is limited
• Review whether any schemes have been unintentionally left open from previous years

Recent updates have simplified certain reporting requirements, including how some share transactions are recorded, but accuracy and consistency remain essential.

How Verallo can help

With multiple scheme types, reporting nuances, and strict deadlines to manage, ERS compliance can become complex quickly, particularly for growing businesses or those operating internationally.

If you would like support reviewing your share schemes or preparing your ERS filings ahead of the 6th July 2026 deadline, Verallo can help ensure everything is accurate, complete, and submitted on time.

Get in touch with the Verallo team to discuss your requirements.