ERS Reporting 6 July 2025 Deadline

Understand ERS Reporting Before It’s Too Late

If your business has offered shares, options, or other securities to employees or directors—at any point—you’re likely required to file an Employment Related Securities (ERS) return with HMRC.

This obligation exists every year, even if no events have taken place within the scheme. With the deadline for the 2024/25 tax year set for 6 July 2025, now is the time to get compliant and avoid penalties.

What is ERS Reporting?

ERS reporting is HMRC’s way of monitoring the tax implications of share-based payments. If your company has issued shares, granted options, transferred ownership of shares, or had employees dispose of securities, these events are likely reportable.

Even tax-advantaged schemes like EMI (Enterprise Management Incentive), CSOP (Company Share Option Plans), SAYE (Save As You Earn), and SIP (Share Incentive Plans) fall under this requirement. And where EMI schemes are in place, annual returns are mandatory every year—even if no activity occurs.

When ERS Reporting Applies

ERS reporting is required in several scenarios:

• Issuing Shares or Securities: If employees receive shares or similar instruments as part of their employment.
• Granting or Exercising Share Options: Includes both approved and unapproved options.
• Transferring Shares or Securities: Whether it’s as a bonus, part of a reward scheme, or any other form of employment-related benefit.
• Disposing of Shares at More than Market Value: If an employee sells shares and makes a gain, it must be reported.

Once your company registers an ERS scheme, it must file a return annually, regardless of whether any activity has occurred.

Key Deadlines and Actions

The scheme must be registered with HMRC and the return submitted via its online service by 6 July 2025. Missing this deadline will automatically trigger a financial penalty.

Don’t forget: Even if there has been no activity, a nil return is still legally required. Failing to submit any return is treated as non-compliance.

Consequences of Missing the Deadline

Not meeting the reporting deadline leads to growing penalties. The first fine may be small, but if delays continue, the fines will increase and could eventually lead to daily charges. Additionally, failing to comply repeatedly can harm your business’s reputation during investor reviews, audits, or when selling the business.

How to Stay Compliant with ERS

Here are your key steps to remain compliant:

• Register Your Scheme: Make sure your scheme is properly registered through HMRC’s online ERS service. This will generate a scheme reference number, which you’ll use annually.
• Track and Record All Activity: Maintain accurate and up-to-date records of share grants, transfers, exercises, and disposals. Use a central log to ensure nothing gets missed.
• Submit the Annual ERS Return: Whether or not there’s been any movement in your scheme, the return must be filed by 6 July each year. This is done via your Government Gateway login.
• Review Your Position Annually: Check which schemes are still active and ensure all required returns are submitted—even for schemes with no activity or which are dormant.

Why This Matters Beyond Compliance

Failure to comply with ERS reporting can have broader implications:

• Loss of tax benefits under schemes like EMI if reporting obligations are missed.
• Delays in business sales or fundraising—missing ERS returns are red flags in due diligence.
• Increased scrutiny from HMRC and potential retrospective penalties.
• Damage to reputation with investors, boards, or stakeholders.

ERS reporting is one of the simplest compliance tasks to stay on top of—but also one of the most commonly overlooked. With more businesses offering equity incentives, getting this right is essential for protecting your tax position, supporting business transactions, and maintaining a strong reputation with HMRC.

Take action now—review your schemes, register if needed, and prepare your ERS return well before the 6 July 2025 deadline.