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United Kingdom·GOV.UK

HMRC confirms one-row net-settlement reporting for all tax years

The August share-schemes bulletin also highlights SAYE restrictions on third-party arrangements and plans to replace separate EMI grant notifications from April 2027.

By Taxxa AI Oy · Published 4 August 2026

Tax

Employers reporting net settlement on the Non-Tax Advantaged Share Schemes (Other) end-of-year return need complete only one row for each individual employee, HMRC confirms in its August employment-related securities bulletinGOV. The approach applies to all tax yearsGOV and replaces the previous requirement for two lines of information.

This reporting change, previously announced in the January 2026 bulletin, leaves the return template's format and structure unchanged. Employers must still retain records showing that Income Tax and National Insurance contributions were accounted for correctly, including how amounts were recovered from employees. HMRC says those records should be kept for the current tax year plus six years and produced if requested during a routine compliance check.

The bulletin also highlights restrictions affecting Save As You Earn arrangements. A SAYE scheme must meet Schedule 3 requirements and be linked to a certified savings arrangement. Paragraph 24 of that Schedule requires shares acquired on exercise to be paid for with money not exceeding the repayments and interest under the approved certified arrangement.

HMRC has expanded its SAYE manual to refer to paragraph 21 of the prospectus. Its guidance says this prohibits transferring the savings contract or any of its benefits to a third party. The bulletin expressly includes a loan arrangement under which any part of the value of the shares, or any profit made, is given up or transferred to a third party. This is presented as clarification of the prospectus requirements, rather than a new reporting concession.

Separately, draft legislation proposes removing the requirement to notify HMRC of an Enterprise Management Incentives option grant separately from the annual returnGOV. The proposal applies to options granted on or after 6 April 2027GOV. Instead, companies would have to report grant details through the EMI end-of-year return for the options to qualify for EMI tax relief.

HMRC says the revised return would start with the 2027–28 tax year and be submitted from 6 April 2028GOV. The technical consultation on the draft closed on 7 September 2026GOV. The bulletin describes separate grant notification as a current requirement, so the proposed future simplification should not be treated as having already removed it.

The existing SAYE framework is Schedule 3 to the Income Tax (Earnings and Pensions) Act 2003 and the certified SAYE prospectus, including paragraph 21 as explained by HMRC.

Use one row per employee for net-settlement reporting, retain the required tax records, and review SAYE third-party arrangements while maintaining current EMI grant notifications.

Sources

  1. Employment related securities bulletin 68 (August 2026)
  2. Schedule 3 SAYE option schemes: Linkage to Savings (Arrangement): Required links
  3. Enterprise Management Incentives (EMI): simplification of the process to grant options

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