A Reminder – HMRC Share Option reporting deadline approaching

If your company has issued shares, granted options, or operates any employee share arrangements, there is a key date that is easy to miss: 6 July 2026.

This is the deadline for submitting your annual Employment Related Securities (ERS) return to HMRC for the 2025/26 tax year (ending 5 April 2026).

This requirement applies where a company operates a share plan or share. In a group, the filing is typically made under the plan company’s  ERS registration with HMRC.

Each year, well‑run businesses get caught out — not because they ignore compliance, but because ERS reporting responsibility can fall between teams or advisers. This note explains what the ERS annual return is, who files it, and the common areas where things go wrong.

What is the ERS annual return?

ERS is HMRC’s annual reporting for shares and share‑related awards connected with employment. HMRC requires a return every year for all schemes/arrangements, including one‑off awards or gifts of shares. A nil return may also be required even where there has been no activity in the year.

The key deadline: 6 July 2026

HMRC’s deadline is 6 July following the end of the tax year. So for the tax year ending 5 April 2026, the filing deadline is 6 July 2026. If you submit after this date, HMRC says you may have to pay a penalty.

Who is responsible for ERS filing?

The responsibility for ensuring a return is made is the Company’s, although they may delegate this task to an agent acting on the company’s behalf (where properly authorised).

A common misconception is that our accountant will do it automatically or we don’t have a share plan, so it won’t apply. HMRC’s guidance is clear that annual ERS reporting can apply even where arrangements are one‑off or informal.

Common ERS problem areas we see

• We don’t have a share plan thinking  –   ERS reporting is broader than many companies expect. HMRC explicitly mentions one‑off awards and gifts of shares as within scope.
• Nil returns overlooked – Businesses often miss the deadline because they assume nothing happened, so nothing is due. HMRC states that you may still need to submit a return (including a “nil return”) in certain situations even where there were no transactions.
• Responsibility gaps (the “someone else is doing it” trap) – ERS reporting is frequently missed because different parts of the business assume another team (or an adviser) is handling it. As the return must be submitted through HMRC’s ERS online service (by the company or an authorised agent), appointing a clear owner early and ensuring the right access is in place can prevent late filing.
• EOT‑owned companies with employee incentives – If a company is EOT‑owned and also grants options or makes share awards, it still falls under the same ERS reporting rules that apply to companies generally.

Practical steps to take now

We recommend that companies:

• Confirm what exists: identify any ERS schemes/arrangements (including historic or one‑off awards) and whether a return or “nil return” is expected.
• Confirm ownership and access: decide who prepares and who reviews, and ensure the ERS online service process and authorisations are in place (whether filing internally or via an agent).
• Start early: allow time to resolve questions and avoid last‑minute pressure ahead of 6 July.

How we help

At RM2, we support companies (including EOT‑owned companies) by helping them:

• confirm whether ERS reporting is required (including nil returns);
• coordinate input across your Finance/Payroll/HR/Legal;
• prepare returns & ensure your filing is submitted on time and in a controlled way.

We file over 150 returns each year for our clients, so if you would like support for the 6 July deadline, please contact us at enquiries@rm2.co.uk.