UK ERS Filing: What Every Company With a UK Share Scheme Needs to Know Before 6 July, 2026

Key Takeaways

• The 2025/26 UK ERS return is due on or before 6 July, 2026
• A return, or nil return, is potentially required for every scheme registered with HMRC, even with zero activity
• ERS applies to both tax-advantaged schemes (CSOP, EMI) and non-tax-advantaged ("Other") arrangements
• Late filing can trigger penalties and adverse tax implications
• Filing responsibility sits with the employer, or an authorised agent on the company's behalf

What is ERS?

ERS stands for Employment Related Securities, HMRC's annual reporting regime for share schemes and share-related awards by reason of employment . If your company has granted equity to anyone in the UK, whether through a formal scheme or an informal arrangement, ERS is very likely relevant to you.

The regime covers reportable events that happen during the UK tax year, which runs from 6 April to 5 April. Reportable events span a wide range, from the grant of an award to its exercise, and other equity-related events in between.

The Deadline That's Easy to Miss

The annual ERS return is due by 6 July following the end of the relevant tax year. For the 2025/26 tax year, covering 6 April 2025 through 5 April 2026, that return is due on or before 6 July 2026.

For companies managing equity across several countries, a single UK deadline can get buried under everything else on the compliance calendar. But HMRC doesn't make exceptions for a busy quarter.

The Nil Return Trap

Here's the detail that trips up more companies than it should: a return must be submitted for every scheme registered with HMRC, even if there were no transactions or reportable events during the year.

For non-tax-advantaged "Other" arrangements, registration is generally triggered by a reportable event. But once an arrangement is registered on the ERS online service, the annual filing obligation continues unless the scheme is properly ceased, including nil returns where there is no activity.

It's a natural assumption that no activity means nothing to report. It's also incorrect. If a scheme is registered, HMRC expects a filing regardless of whether anything actually happened under it, a nil return, but a required one all the same. Companies that let a dormant or inactive scheme fall off their radar are exactly the ones most likely to miss this.

Tax-Advantaged and Non-Tax-Advantaged Schemes Alike

ERS reporting isn't limited to formal tax-advantaged structures. It applies to:

• Tax-advantaged schemes, such as CSOP and EMI
• Non-tax-advantaged ("Other") schemes or arrangements

If a scheme is registered with HMRC, it's in scope, regardless of which category it falls into.

Who's Responsible

Filing responsibility generally sits with the employer. In most cases, the employer submits the return directly, or an authorised agent files on the company's behalf. Either way, the obligation doesn't disappear just because a scheme has gone quiet.

What's at Stake

Late filing isn't a minor administrative slip. It can trigger penalties, and in some cases, adverse tax implications.

The Bigger Pattern

UK ERS is a useful case study in a broader problem: equity compliance obligations don't stop existing just because there's no activity to report, and they don't wait for a convenient moment on the calendar. For companies with equity programs spanning multiple countries, tracking every registered scheme's filing status, active or dormant, by spreadsheet and memory is exactly how deadlines like 6 July get missed.

If your company has a UK share scheme registered with HMRC, this is the moment to confirm what's due, whether that's a full return or a nil return.