GOV.UK
Enterprise Management Incentives (EMI): Eligible employees: Employment requirement
Individuals are only eligible for EMI options if they are employees of the company whose shares are the subject of the options, or, in the case of a group, employees of any qualifying subsidiary of that company.
Directors are classed as employees of a company, and so as long as directors meet the criteria set out for employees they will also qualify for EMI, (Paragraph 25).