EMI Share Option Reporting Set to Get Simpler for Employers from April 2027
If your business offers Enterprise Management Incentive share options, and you’ve ever grumbled about reporting the same grant to HMRC twice in slightly different ways, there’s some good news. HMRC has published draft legislation aimed at simplifying EMI reporting, and while it’s a modest change on paper, it removes a genuinely annoying piece of administrative duplication.
What EMI is, briefly
EMI is a tax-advantaged employee share scheme available to qualifying companies, designed to help businesses recruit, retain and reward staff by granting share options with favourable tax treatment compared with unapproved schemes. It’s particularly popular with growing SMEs that want to offer equity without the cost of a fully unapproved arrangement.
The current duplication
At the moment, companies granting EMI options have to do two separate things: notify HMRC when the options are granted, and then complete a full annual return by 6 July following the end of the tax year, which repeats much of the same information. It’s a small extra task, but it’s exactly the kind of duplicate admin that’s easy to miss or get slightly wrong, particularly for smaller companies without a dedicated share scheme administrator.
What’s being proposed
Under the draft legislation, the standalone grant notification would be folded into the existing annual EMI return, so companies would only need to report once a year rather than notifying separately at the point of grant and then again annually. HMRC’s consultation on the change closed on 7 September 2026, and if it goes ahead as drafted, it would apply to EMI options granted on or after 6 April 2027.
As the consultation document puts it, “the proposal represents a relatively small administrative change, but one that should remove duplication from the current process and simplify reporting for employers operating EMI schemes.”
Why this matters for employers
If you already run an EMI scheme, this is a welcome, if unglamorous, reduction in admin from April 2027 onward. It doesn’t change the tax treatment of options, the qualifying conditions for EMI, or anything around exercise, release or lapse of options, so this isn’t a moment to review your scheme’s fundamentals. It’s simply one less form to remember.
The main practical point is timing. Anything granted before 6 April 2027 will still follow the current dual-reporting process, so businesses running EMI schemes shouldn’t assume the simpler approach applies retroactively or to grants made in the current tax year.
What to do now
- Keep the current grant notification and annual return process running as normal until the April 2027 change takes effect.
- Flag the change to whoever administers your EMI scheme, so grants made from April 2027 aren’t accidentally double-reported under the old process.
- Watch for final legislation and HMRC guidance confirming the detail, since the consultation has only just closed.
How Pecunia Pro can help
Share scheme administration sits alongside a lot of the payroll and reward work we do for clients. If you’d like a hand keeping EMI reporting on track, either now or once the new process beds in, we’re happy to help.
Want help getting ahead of this? Call us on 020 8143 1529 or email info@pecuniapro.co.uk and we’ll talk it through.