EMI Filing Requirements
📘 Overview
If your company operates an Enterprise Management Incentive (EMI) scheme, there are strict deadlines for signing documents, registering the scheme, and notifying HMRC.
Missing these deadlines could cause your EMI options to lose their tax advantages, so it’s important to plan ahead.
This guide covers the key dates, registration process, and notification steps, including what Barnes & Scott can do on your behalf.
⏰ Key Deadlines
| Requirement | Deadline | Details |
|---|---|---|
| Sign EMI legal documents | Within 60 days of HMRC valuation agreement | Option agreements and board minutes must be signed before the valuation expires. |
| Notify HMRC of new EMI options | By 6 July following the end of the tax year in which the grant was made | Late notification may invalidate EMI tax advantages. |
| Register EMI option scheme | Before you can notify HMRC | This can take up to 10 working days for HMRC to approve. |
| Annual EMI return | By 6 July each year | Required even if there are no new grants; confirms lapses or cancellations. |
💡 You can make EMI notifications yourself, or Barnes & Scott can submit them on your behalf once authorised.
📝 Registering an EMI Option Scheme
You must register your EMI scheme before any notifications can be submitted.
HMRC does not permit agents (including Barnes & Scott) to complete this initial registration, however, we can assist you through the process if you provide temporary access to your HMRC account.
Step 1: Set up PAYE Online
If you haven’t already done so, you’ll need a PAYE online account for employers.
This setup can take up to 10 working days, so start early.
Step 2: Register Your Scheme
Once PAYE online is active:
- Log in to your HMRC Online Services.
- Navigate to Employment Related Securities.
- Select Register a scheme > EMI.
- Follow the on-screen instructions.
📎 Tip:
Take a screenshot or note the unique reference number provided when you register, you’ll need this to make your EMI grant notification later.
💼 Making an EMI Notification Yourself
You must notify HMRC of any EMI share option grants by 6 July following the end of the tax year in which they were made.
How to Notify HMRC
You can report grants for up to 30 employees using one of two methods:
Option 1 – ERS Online Service
- Log in to HMRC Online Services.
- Continue past the security message.
- From the left-hand menu, select Services you can use.
- Choose PAYE for Employers.
- Scroll to the Employment Related Securities section and click EMI notifications.
- Follow the on-screen instructions.
You’ll need your EMI scheme reference number from registration to complete this step.
Option 2 – EMI Notification Template (for 30+ employees)
If you’re notifying grants for more than 30 employees, you must complete and send HMRC an EMI Notification Template.
Guidance on how to fill in key fields (columns G–J) is available on HMRC’s website.

🤝 Barnes & Scott Can Notify HMRC on Your Behalf
While we can’t register the EMI scheme, Barnes & Scott can submit EMI notifications for your company once we’re authorised to access your PAYE account.
What We’ll Need
To set up access, please provide:
- Your Employer PAYE Reference
- Your Accounts Office Reference
Once submitted, HMRC will send an authorisation code to your registered office address.
This can take up to 10 working days.
As soon as you receive the code, please share it with us so we can finalise access and submit your EMI notifications before the deadline.
✅ Summary
| Task | Who Does It | Deadline / Timing |
|---|---|---|
| Sign legal documents (option agreements, board minutes) | Company | Within 60 days of HMRC valuation approval |
| Register EMI scheme | Company (with B&S support if needed) | Before notification; allow 10 working days |
| Notify HMRC of new grants | Company or Barnes & Scott | By 6 July following tax year end |
| Submit annual EMI return | Company | By 6 July each year |
| Authorise Barnes & Scott (if applicable) | Company | Allow 10 working days for HMRC to issue code |