UK Share Plan Reporting 2026: Deadlines, Requirements and Key Steps for International Employers

UK share plan reporting obligations remain a critical compliance requirement for multinational organisations with employees in the United Kingdom. In this update, Abbiss Cadres, UK member firm of CELIA Alliance, outlines the key requirements and practical steps for 2026 reporting.

As the 2025/26 tax year reporting deadline approaches, employers must ensure they meet their Employment Related Securities (ERS) obligations with HM Revenue & Customs (HMRC), the UK’s tax authority, to avoid penalties and preserve the tax advantages associated with share plans.

At a glance: UK share plan reporting requirements

Employers must:

• Register all new share plans or arrangements with HMRC
• Submit an annual ERS return for each registered plan
• File nil returns where no reportable activity has occurred
• Ensure tax-advantaged plans are properly self-certified

When is the deadline for UK share plan reporting in 2026?

The deadline for submitting ERS annual returns for the 2025/26 UK tax year is:

• Midnight (UK time), 6 July 2026

All filings must be completed through HMRC’s online ERS reporting system.

Employers not yet registered should do so by 22 June 2026 at the latest, as access and system activation can take several days.

Who needs to complete ERS reporting?

ERS reporting obligations apply broadly to any employer with share-based compensation involving UK employees or directors.

This includes organisations that have:

• Share options or equity awards granted to UK employees or directors
• Securities linked to UK employment duties
• International share plans with UK participants

This captures:

• UK-headquartered businesses
• Overseas parent companies granting equity to UK-based employees
• Multinational employers with internationally mobile employees performing duties in the UK

What events should be reporting to HMRC?

Employers must report any relevant activity involving employment-related securities (ERS), including:

• Grants of rights to acquire shares or securities
• Acquisition of shares or securities by employees
• The lifting of restrictions (e.g. vesting or forfeiture conditions)

New share plan registrations

A new ERS registration is required where:

• A new share plan is introduced
• A corporate transaction creates new equity or incentive arrangements
• Existing registrations do not cover new awards

Once registered, HMRC will issue a unique scheme reference number, which is required for annual filings.

As processing can take up to 10 days, early registration is essential.

It is important to note that while advisers can assist, the registration itself must be completed by the employer.

Employers should also be aware that tax advantages for qualifying share plans depend on correct registration and compliance.

Do share plans need to be self-certified?

Yes. Employers operating UK tax-advantaged share plans must confirm compliance with statutory requirements.

This applies to schemes such as:

• Share Incentive Plans (SIP)
• Save As You Earn (SAYE) schemes
• Company Share Option Plans (CSOP)

Self-certification must be completed at the point of registration or when the first awards are granted.

Common share plan reporting errors to avoid

• Excluding internationally mobile employees
Employees working partly in the UK may still trigger reporting obligations.

• Omitting non-executive directors
These individuals must be included in the appropriate return category.

• Duplicate or incorrect scheme registration
Registering the same plan more than once is a common issue that can lead to penalties.

• Missing deadlines or failing to submit nil returns
A return is required even where no reportable activity has occurred.

Reminder: The deadline is 6 July 2026.

• Incorrectly ceasing a scheme
Only the employer (not an agent) can formally close a scheme via HMRC’s system.

• Errors in HMRC templates
Altering templates (e.g. deleting columns or changing formats) can cause submission failures.

Are there any penalties for late filing?

Late or missed filings can result in escalating penalties:

• £100 initial penalty per return
• £300 additional penalty after 3 months
• £300 additional penalty after 6 months
• £10 daily penalties after 9 months

In addition to financial penalties, clients risk losing the tax-advantaged status of their share plans.

How can CELIA Alliance support you?

Through its UK member firm Abbiss Cadres, CELIA Alliance provides specialist support on UK share plan reporting and broader cross-border reward compliance.

Support includes:

• Registration of share plans with HMRC
• Self-certification of tax-advantaged schemes
• Preparation and submission of ERS returns
• Review and optimisation of reporting processes
• Advice on international share plan structures and mobile employees
• Data protection and compliance considerations

Training sessions and practical walkthroughs of the HMRC reporting system are also available.

Get expert support

If your organisation operates share plans involving UK employees, now is the time to ensure your reporting processes are robust and compliant ahead of the 2026 deadline.

To discuss your requirements or obtain tailored advice, please get in touch with your local CELIA Alliance member firm.