EMI Share Options: HMRC to Scrap Standalone Grant Notifications From 2027

What's changing for EMI schemes

Draft legislation published on 13 July 2026 (consultation closes 7 September 2026) confirms that from 6 April 2027, companies granting Enterprise Management Incentive (EMI) share options will no longer submit a separate notification to HMRC within 92 days of grant. Instead, every EMI option grant will be reported through the EMI end of year return, starting with the return for the 2027/28 tax year (due by 6 July 2028).

Why it matters if you grant EMI options

• EMI remains the most tax-efficient way for many SMEs — especially IT, tech and other fast-growing companies — to give key staff equity

• Missing the current 92-day notification deadline can disqualify options from EMI tax reliefs entirely, and that risk doesn't disappear under the new rules — it just moves to getting the annual return right

• Good internal record-keeping becomes even more important, since HMRC will no longer see each grant individually and in real time

• HMRC's Employment Related Securities Bulletin 68 (August 2026) also confirms other changes: the non-tax-advantaged share schemes end of year return moves to one row of information per employee instead of two, and guidance has been tightened on Save As You Earn (SAYE) schemes to block employees transferring savings contracts or using them as loan collateral

What tech and growing businesses should do now

• Keep filing the current 92-day EMI notification for every grant until 6 April 2027 — nothing changes before then

• Start (or tighten) an internal EMI grant register now: option holder, grant date, exercise price, number of shares and valuation used, so the move to annual-return-only reporting is a formality rather than a scramble

• If the change affects how you administer share schemes, the consultation on the draft legislation closes 7 September 2026

• Review whether your existing HMRC-agreed EMI valuations are still current, especially ahead of a funding round or exit

FAQ

Do I still need to notify HMRC within 92 days of granting EMI options?

Yes. Nothing changes until 6 April 2027. Miss the current 92-day window before then and you risk losing EMI tax reliefs on those options.

What happens to grants made after April 2027?

They won't need a standalone notification. Details will instead be captured on the EMI end of year return covering the 2027/28 tax year, due by 6 July 2028.

Does this change how EMI valuations work?

No. You'll still need to agree a valuation with HMRC (or use an appropriate valuation approach) before granting options — only the notification mechanic is changing.

Is this relevant if we use SAYE rather than EMI?

The same August 2026 HMRC bulletin also tightened guidance on SAYE anti-avoidance rules, so it's worth reviewing both types of share scheme together if you operate them.

If your company grants EMI options, is thinking about setting up a share scheme, or you just want your current arrangements checked against the latest HMRC guidance, Jackson Lee Accountants can help. Get in touch (https://www.jacksonleeaccountants.co.uk/contact-me).

Sources: Employment Related Securities Bulletin 68 (August 2026) – GOV.UK (https://www.gov.uk/guidance/employment-related-securities-bulletin-68-august-2026)