In order to avoid penalties, companies should be sure to complete mandatory online registrations well in advance of the 6 July deadline.

Companies which operate employee share plans in the UK are required to make a filing with Her Majesty’s Revenue and Customs (HMRC), the UK tax authority, on an annual basis (by 6 July each year). This filing must now be made online via the HMRC Employment Related Securities (ERS) Online Service. The filing must record all “reportable events” which took place (see below for details as to what will constitute a “reportable event”). These filing requirements apply if any UK employees participate in a stock option, RSU or other stock based incentive plan linked to their employment, for example UK employees participating in a US stock incentive plan. Note that the obligation falls upon a US employer if there is no UK employer.