When do EMI options need to be notified to HMRC?

For EMI options granted on or after 6 April 2024, HMRC requires notification of the award by 6 July following the end of the tax year in which the grant was made. This replaced the old 92-day notification window.

Although the notification window is now longer, we strongly recommend treating notification as part of the grant process rather than a year-end task. Missing the deadline puts the EMI tax advantages at risk for both company and option holders — and if an exit or funding round arrives unexpectedly, a buyer’s due diligence team will ask whether grants were properly notified. Notification should always be made before options are exercised.