HMRC Bulletin 62 – EMI Changes

Last Updated on 19 January 2026

HMRC provided a couple of updates in its Bulletin No 62 in December and just in case they got lost in the hustle & bustle of your Christmas preparations we take a look back at their 3 main highlights.

EMI – changes in thresholds

As previously reported the Finance Bill 2026 will expand the limits on Enterprise Management Incentive (EMI) schemes.

From 6 April 2026 the EMI limits increase as noted below, allowing more companies to benefit from using this tax efficient share option plan

• the value of company options which can be issued increases from £3 million to £6 million;
• the limit on value of gross assets held by the company to qualify for EMI increases from £30 million to £120 million;
• the limit on the number of employees for the company to qualify granting EMI options increases from 250 to 500; and
• the maximum holding period for an EMI option increases from 10 years to 15 years.

In addition the change to the maximum holding period can be applied retrospectively to existing contracts which haven’t expired or been exercised, providing the contacts have been amended in-line with the legislation.

EMI Reporting

Previous changes removed the requirement for you to report a grant of an EMI option within 92 days and to simply make the notification in line with the time frames of other plan reporting. i.e. by 6th July following the end of the tax year.

Simplification takes another step forward and legislation will be introduced by the Finance Bill 2027 to remove the requirement to notify the grant of EMI options separately.  Therefore from 6th April 2027 the notification of EMI options will be included on your standard EMI end of year return.

PISCES

Legislation has been amended following feedback to allow existing Enterprise Management Incentive (EMI) & Company Share Option Plan (CSOP) contracts that are granted prior to April 2028 to be amended to include a sale on a PISCES platform and classify the sale as a specified exercise event.

If you make these changes to your EMI & CSOP contracts you will need to notify your participants, but making the change this won’t classify as a change to the fundamental terms of the option and therefore the tax advantages of the options will remain intact (assuming all other requirements of the scheme are met).

Further good news is that there will be no changes to HMRC’s Employment Related Securities (ERS) reporting templates in this regard.

How we can help

RM2’s team of expert employee ownership specialists have been supporting clients with share scheme and employee ownership arrangements for nearly 30 years.

If you have any questions, or are considering the grant of EMI options now that the thresholds have been increased, please drop us a line at enquiries@rm2.co.uk and we can schedule a call with one of our expert advisers on how we can assist you.