How to notify HMRC about your EMI scheme

• Granted before 6 April 2024: notification was due within 92 days of the grant date.

• Granted from 6 April 2024 to 5 April 2027: notification is due by 6 July following the end of the tax year in which the options were granted. For example, options granted any time between 6 April 2025 and 5 April 2026 must be notified by 6 July 2026.

• Granted from 6 April 2027: the Government has proposed removing the separate grant notification altogether, with grant details instead reported through the EMI annual return. This is not yet law. It remains subject to the Finance Bill 2026 to 2027, and the detailed reporting process hasn't been confirmed. We'll update this page once it is.

If any of your options were granted before 6 April 2024 and haven't yet been notified, the old 92-day rule still applies to them. Ask a professional if you're unsure where you stand.

Notification is done by logging into HMRC's Employment Related Services (ERS) website.

If you do not have a Government Gateway user ID and password, you will need to sign up for one in order to make your initial notification to HMRC. HMRC will request your full name, email address, and a password to create this account.

You will later use this same account to make notifications about option grants and file yearly returns (see below).

Once you have set up or logged into your account, notify HMRC about the creation of your EMI options scheme by following the guidelines on this page.

You will receive a reference number from HMRC within seven days of registering your scheme. Once you have received this, you will be eligible to notify HMRC about EMI option grants.

EMI option grant notifications

To perform notifications regarding your EMI option grants, you will need your Government Gateway user ID and password (which you should have previously used when you first notified HMRC about your EMI scheme).

If you have 30 or more employees, you'll also need to download and complete this EMI notification template and upload it to HMRC when it is completed.

For options granted from 6 April 2024 onwards, you have until 6 July following the end of the relevant tax year to notify HMRC, a much longer window than the old 92-day rule. Because that deadline is often many months away, it's worth notifying HMRC well ahead of 6 July rather than leaving it until the last minute, since that date is also when annual returns fall due and HMRC's systems tend to get busy.

Yearly EMI returns

In addition to option notifications, an EMI annual return via ERS must be submitted by your company by 6 July of each year. This return must include any significant activity that has occurred in the prior tax year.

If nothing has happened in the year, in terms of restructuring or options being cancelled, altered, or exercised, a return must still be completed, but will state that nothing has occurred.

If there has been any of the above activity, an end of year template will need to be filled in summarising the information.

Your company must submit its annual return electronically. If you are unable to file online for some reason, HMRC requests that you share your reason by post:

Employee Shares & Securities Team Room G47 100 Parliament Street, London SW1A 2BQ

If you do not file your return and any information accompanying it electronically, you may face a penalty, unless HMRC has agreed in advance that you may file some other way.

For more information on contacting HMRC about your options, please consult this GOV.UK page.