File your 2024-2025 HMRC annual ERS return before 6 July deadline

Employers are reminded that the deadline to submit your annual Employment-Related Securities (ERS) return with HMRC is 6 July 2025.

An ERS return must be filed by all employers who operate share schemes (whether tax-advantaged schemes – such as EMI, CSOP, SAYE or SIP plans etc – or not), or have otherwise awarded any securities (including shares, loan notes and share options) to any current or former employees or directors (including non-executive directors) in the 2024-2025 tax year (“ERS Schemes and Awards”).

The ERS return needs to be filed online via the HMRC online portal (part of the HMRC PAYE online service), and before you can make an annual return, your ERS Scheme must first be registered with HMRC through the ERS online service.

The filing process can be time-consuming and tricky to navigate, so you need to start the process early (particularly if you need to register a new ERS Scheme prior to making the submission). If you miss the deadline, you will be charged an automatic £100 late filing penalty (with further penalties due after 3, 6 and 9 months). HMRC also have discretion to impose penalties of up to £5,000 if your ERS return contains any material inaccuracies.

You should also note that the 6 July 2025 deadline falls on a Sunday this year, so we recommend you ensure the process has been completed and that HMRC has everything it needs from you by Friday 4 July at the latest.

Examples of what the ERS return needs to cover

The return covers transactions involving ERS Schemes and Awards which have taken place in the period from 6 April 2024 to 5 April 2025. Common examples of transactions that have to be notified include, but are not limited to:

• The acquisition of any shares or securities by any current and former employees and/or directors (including NEDs).
• The grant and exercise of share options (in particular you need to notify any EMI options granted) to or by any current and former employees and/or directors (including NEDs).
• Changes of any rights and/or restrictions of any shares or securities held by any current and former employees and/or directors (including NEDs).
• The sale (in certain circumstances) of any shares or securities held by any current and former employees and/or directors (including NEDs).
• The cancellation or exchange of any shares or securities held by any current and former employees and/or directors (including NEDs). 

Even if there have been no reportable events since 6 April 2024, you must submit a ‘nil return’ for any ERS Scheme that has previously been registered by you.

Practical tips

• All your non tax-advantaged arrangements (i.e. plans other than EMI, CSOP, SAYE and SIP plans) can be registered under a single reference number and a return submitted on the “other” template.
• In contrast, each of the tax-advantaged plans (EMI, CSOP, SAYE and SIP) must be registered and reported separately.
• The return will be rejected if it contains formatting errors, so it is a good idea to take advantage of the HMRC checking service before submitting your return.   
• Before you submit your returns, you should save a copy for your own records.  Take screenshots of each page before submitting and save them together with a copy of the confirmation page. This is because the HMRC online service won’t save these details and you won’t be able to access them again.

Need further guidance?

HMRC provide online guidance on making the return and provide some useful templates that you can use in the process of filing the return:

• HMRC templates and guidance: https://www.gov.uk/government/collections/employment-related-securities
• HMRC checking service: https://www.gov.uk/guidance/spreadsheet-checking-service-employment-related-securities-ers
• Further information about the process for registering your ERS Schemes and Awards: https://www.gov.uk/guidance/tell-hmrc-about-your-employment-related-securities

How we can help

If you require further support with your filing obligation or require general advice on the establishment or operation of any ERS Scheme or Award, please do not hesitate to contact the Fox Williams Tax and Incentives team, who can assist you further.