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EMI expansion 2026 - biggest change in 20 years

What is your equity actually worth?

Model the after-tax difference between EMI, CSOP, unapproved options, growth shares and ordinary shares. For you, and for your whole company.

EMI rule changes in force from 6 April 2026
Employee limit
Up to 250 employees
500 employees
Companies that pivoted to CSOP at the 250 threshold can now return to EMI. Note: any CSOP grants count (at UMV at grant) toward the individual EMI limit.
Gross assets
£30m limit
£120m limit
Capital-heavy scale-ups in tech and life sciences are now eligible.
Aggregate EMI limit
£3m at any one time
£6m at any one time
Total value of granted and unexercised EMI options the company can have at any one time. More room to bring people in.
Exercise window
10 years from grant
15 years from grant
Applies to new grants from April 2026. Existing options can also be extended by board approval, but it is not automatic.
Changes apply to EMI options granted on or after 6 April 2026. The extended exercise window is available for existing options too, but the extension is an active board decision rather than automatic.

Your personal equity scenario

Choose your scheme type and enter your grant details. We will show you what you keep after tax at exit, and how that compares to EMI. Modelling is based on UK tax rules and assumes a UK-resident employee.

Your option or share grant

Select your scheme and enter your numbers. All figures in GBP.

Scheme type
Grant details

Number of options held under the scheme.

£

Set at AMV at grant for full EMI tax efficiency.

£

AMV when granted. If above the exercise price, the discount is taxed as income at exercise (RCAs).

Valuation and exit
£

Per-share value at the eventual exit.

Your tax position
£

Used to determine your income tax band. Modelling assumes a UK-resident employee.

For general informational and educational purposes only. The information provided in this tool does not constitute financial, investment, or tax advice. Figures are indicative - modelling UK tax outcomes for a UK-resident employee or optionholder using current rates and standard band logic. Actual liability depends on individual circumstances such as personal allowance taper, other income sources, share scheme structuring, RCA status and qualifying conditions. Always consult a qualified professional or seek independent advice regarding your specific circumstances before making any financial decisions.

Your whole company

Scale the analysis across your full equity scheme. What does the right scheme choice mean for your whole team, and for your balance sheet?

Building on your personal scenario

Your individual figures carry through below. Adjust the team-wide inputs to model the full picture your board needs to see.

From stage 1
Your schemeEMI
Net under your scheme£0
Net under EMI£0
Your personal saving£0

Your full equity scheme

Team-wide scheme details. All figures are averages across the scheme.

Headcount and grants
Pricing
£
£
Workforce
£

Modelling assumes UK-resident employees.

Company tax position

Sets the value of the Part 12 CT deduction.

Total scheme value at exit
£0
Gross gain across all employees
Employee saving with EMI
£0
Extra take-home vs CSOP
Scheme Gross gain Total tax Net proceeds vs CSOP
Enter details above

Corporation tax relief

The Part 12 deduction. The biggest company-side benefit, and the one most boards miss.

Under Part 12 of the Corporation Tax Act 2009, the company gets a statutory corporation tax deduction equal to the gain at exercise (market value minus exercise price) for EMI, CSOP and Unapproved options. This applies even when the employee pays no income tax. EMI is the standout: the company gets the full deduction while the employee is exempt from income tax and NIC. No other UK incentive structure offers this combination.

Deduction available at exercise
£0
EMI, CSOP and Unapp
CT rate applied
25%
Main rate, 2025 to 2026
Corporation tax saved
£0
Cash benefit to the company
Growth shares note. Growth shares typically attract no Part 12 deduction because there is no employment income charge to deduct against. If a Section 431 election is made and shares are subscribed at unrestricted market value, the deduction is nil. This is one of the trade-offs against options.

Employer NIC saving

A direct balance-sheet benefit that is often overlooked.

Under unapproved options, and CSOP exercised outside approved terms, the company pays secondary Class 1 NIC at 15% on the gain at exercise. Under EMI, no employer NIC is due on exercise as long as the exercise price was set at or above AMV at grant. CSOP options exercised on Exit or 3+ years after grant (or under one of the HMRC exemption clauses) also avoid NIC for both the company and the recipient.

CSOP or Unapp employer NIC
£0
EMI employer NIC
£0
Company saving
£0
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For general informational and educational purposes only. The information provided in this tool does not constitute financial, investment, or tax advice. Figures are indicative - company-wide modelling uses averaged inputs for UK-resident employees, and tax treatment varies by individual and scheme design. Employer NIC assumes CSOP exercised outside approved terms or unapproved options. EMI is exempt from employer NIC on exercise when granted at or above AMV. Ordinary share modelling at company level assumes shares paid at full market value; if employees acquired below MV, employment income would arise on the spread. Always consult a qualified professional or seek independent advice regarding your specific circumstances before making any financial decisions.

Why EMI is the most tax-efficient option scheme

How the maths breaks down. The features below explain why EMI consistently produces the strongest after-tax outcome across the schemes modelled here.

EMI
No income tax on exercise
When the exercise price equals AMV at grant, EMI options are exempt from income tax and NIC at exercise. Only CGT applies at disposal.
BADR
Business Asset Disposal Relief
EMI gains qualify for BADR without the usual 5% personal company test. 14% to April 2026, then 18%. Standard CGT is 24%.
NIC
No employer NIC
EMI is exempt from secondary Class 1 NIC at 15% on the exercise gain. A direct balance-sheet saving for the company on every exercise.
£6m
Larger aggregate limit
The total value of unexercised EMI options a company can have outstanding doubles from £3m to £6m. Room to bring more people in.
500
More companies eligible
Employee limit raised from 250 to 500. Gross assets limit raised from £30m to £120m. Many scale-ups that had pivoted to CSOP can now return to EMI.
15y
15-year exercise window
Up from 10 years for new grants from April 2026. Existing EMI options can also be extended via board approval, but this is an active decision rather than automatic.

The acronyms that matter

Three valuation and treatment concepts plus one tax relief that drive every figure in this tool. Worth understanding before you finalise a scheme decision.

BADR
Business Asset Disposal Relief
A reduced 18% CGT rate (up from 14% pre-April 2026) on qualifying business asset disposals. EMI gains qualify automatically after a 2-year holding period - uniquely without the 5% personal company test that other schemes need.
AMV
Actual Market Value
The HMRC-agreed value of a share that takes restrictions into account. EMI requires the exercise price to be at or above AMV at grant - otherwise the discount is taxed as employment income at exercise.
UMV
Unrestricted Market Value
What the share is worth ignoring restrictions. CSOP requires the exercise price to match UMV at grant - set it below and the scheme falls outside CSOP rules. UMV usually sits above AMV.
RCA
Readily Convertible Assets
A share is "readily convertible" when it can be turned into cash quickly - at exit, when listed, or under a trading arrangement. When RCAs apply at exercise, employer NIC and PAYE attach to any taxable amount on top of the income tax itself.