HMRC Notifications for unapproved options

You'll need to complete an annual notification by 6th July

Although the HMRC notification requirements for unapproved options are much less than that for EMI, they do exist if you're issuing unapproved options to UK employees and directors.

Unlike EMI, you don't need to complete an initial notification, but you will need to complete an annual notification by 6th July each year for the previous financial year's activity.

This is a similar process to EMI, in that you first need to register the scheme, then return after about 5 working days to complete the annual notification. So it's important to leave plenty of time before the deadline. 

Follow our help guide on registering an unapproved option scheme. And once that step is complete, follow this guide on submitting your annual notification.

Unapproved options are considered "Other ERS Schemes and Arrangements."

Please follow the guidance for this process, plus the ODS/CSV that must be used for detailed returns here.


Our team, content and app can help you make informed decisions. However, any guidance and support should not be considered as 'legal or financial advice'.