EMI options: remember your 92-day grant notifications

HMRC's notification deadlines for Enterprise Management Incentive (EMI) option grants have changed but don’t get caught out! The changes only apply for options granted on or after 6 April 2024 so you will still need to make a grant notification to HMRC for EMI options granted on or before 5 April 2024 within the usual 92-day window.

For options granted on or after 6 April 2024, the long-standing 92-day deadline for notifying HMRC of new EMI option grants will fall away and EMI option grants must instead be reported to HMRC by 6 July following the end of the tax year in which the options were granted as part of the annual share plan reporting requirements to HMRC.  

The first such deadline is 6 July 2025 for EMI options granted between 6 April 2024 and 5 April 2025. This new reporting requirement for EMI option grants extends the reporting deadline in most cases and so is generally a positive step in simplifying the administratively complex EMI grant process. 

However, given that there could be over a year between the grants of options and their reporting deadline, we strongly encourage companies granting EMI options to keep careful records of those grants throughout the year and to set calendar reminders to ensure they submit their annual share plan return to HMRC by the relevant 6 July deadline. If this deadline is missed, the options will lose their highly beneficial EMI tax status.

As noted above, any EMI options granted before 6 April 2024 will still have to be notified to HMRC within 92 days of the date of grant in order to retain any EMI tax status.

For more information about EMI options, please see our EMI factsheet. If you have any questions about the new EMI grant notification process or would like guidance on your HMRC annual share plan reporting generally, please reach out to the Two Birds’ EIB team – always happy to help.


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