Enterprise Management Incentives (EMI): removal of the requirement to submit a notification of a grant of options
Published 13 July 2026
Who is likely to be affected
This measure will affect companies that use the Enterprise Management Incentives (EMI) scheme, a tax advantaged share scheme available to eligible companies in the UK.
General description of the measure
The measure makes changes to simplify administration of EMI by removing a separate requirement to notify HMRC when companies grant their employees EMI options from 6 April 2027.
Instead, a company will be required to report details of the grant of options through the existing EMI end of year return.
Policy objective
The measure supports companies by simplifying the process to grant EMI options. EMI is targeted tax relief to support small, medium sized and scale up companies with recruitment and retention.
Background to the measure
At Budget 2025, the government announced that it will introduce legislation in a future finance bill to remove the requirement for companies to submit a notification of a grant of EMI options. These changes will apply to options granted on or after 6 April 2027.
Detailed proposal
Operative date
The measure will apply to EMI share options granted on or after 6 April 2027.
Current law
The current law is included in Part 7 and Schedule 5 of the Income Tax (Earnings and Pensions) Act (ITEPA) 2003.
Proposed revisions
Legislation will be introduced in Finance Bill 2026-27 to modify section 527 and Schedule 5 ITEPA 2003.
Section 527 will be revised:
-
to amend the definition of a ‘qualifying option’ for the purposes of EMI, to remove the requirement to provide a separate notification of a grant of options and instead to require the option to be notified through the annual return
-
to make other minor amendments and corrections
Schedule 5 will be revised:
-
to remove the provisions which require a separate notification of a grant of options
-
to require notice of the grant of options to be given in the annual return
-
to define the termination date of a scheme
-
to allow HMRC to require information or declarations to determine that an option meets the conditions for EMI
-
to make other minor amendments and corrections
The proposed revisions will apply to options granted on or after 6 April 2027.
Summary of impacts
Exchequer Impact (£ million)
| 2025 to 2026 | 2026 to 2027 | 2027 to 2028 | 2028 to 2029 | 2029 to 2030 | 2030 to 2031 |
|---|---|---|---|---|---|
| — | — | negligible | negligible | negligible | negligible |
This measure is expected to have a negligible impact on the Exchequer.
Macroeconomic impact
This measure is not expected to have any significant macroeconomic impacts.
Impact on individuals, households and families
There is no impact on individuals as this measure only affects businesses.
Equalities impacts
This measure only affects businesses. Therefore, it is not anticipated that there will be disproportionate impacts on any protected groups.
Administrative impact on business including civil society organisations
This measure is expected to have a significant impact on an estimated 5200 small, medium and scale-up companies granting options under EMI schemes as it will make the process to grant options easier by removing the need to do a separate notification in addition to the end of year return.
One-off costs could include businesses having to familiarise themselves with the new rules. These costs are estimated to be negligible. There are not expected to be any continuing costs.
This is expected to impact companies experience of using EMI as the changes are likely to reduce resources spent on administrative activities associated with granting options. Continuing administrative savings are estimated to be £1.1 million a year across all users.
This measure is not expected to impact civil society organisations.
Estimated one-off impact on transitional business costs (£ million)
| One-off impact | (£ million) |
|---|---|
| Costs | negligible |
| Savings | nil |
Estimated continuing impact on administrative burden (£ million)
| Continuing average annual impact | (£ million) |
|---|---|
| Costs | nil |
| Savings | 1.1 |
| Net impact on annual administrative burden | -1.1 |
Operational impact (£ million) (HMRC or other)
HMRC will need to make changes to its IT systems to support safe implementation of this policy change. These changes are expected to incur a one-off cost in the region of £4 million and will be delivered in two phases.
The separate notification will be removed for options granted on or after 6 April 2027. The end of year return will be updated to require details of a grant of options, beginning with the return for the 2027 to 2028 tax year, which will be submitted from 6 April 2028.
Other impacts
Other impacts have been considered and none have been identified.
Monitoring and evaluation
The measure will be monitored through regular contact with stakeholders and specialist practitioners through the Share Schemes Forum.
Further advice
If you have any questions about this change, contact the relevant team at employmentincomepolicy@hmrc.gov.uk.