Employment related securities bulletin 62 (November 2025)
Source: gov.uk (2025-12-01)

Find out about announcements at Autumn Budget 2025, including Private Intermittent Securities and Capital Exchange System (PISCES), Enterprise Management Incentives (EMI) and the published Summary of Responses to the Share Incentive Plans (SIP) and Save As You Earn (SAYE) 2023 Call for Evidence.

Private Intermittent Securities and Capital Exchange System (PISCES)

PISCES is a new type of stock market for the secondary trading of existing private company shares and is designed to support private companies to scale and grow.

The Financial Conduct Authority have approved the London Stock Exchange and JP Jenkins to operate PISCES platforms.

To ensure the tax system keeps pace with innovation in the wider economy, the government announced on 15 May 2025 that it would introduce legislation in the Finance Bill 2025-26 to allow companies to amend Enterprise Management Incentives (EMI) and Company Share Option Plan (CSOP) contracts to include a sale on a PISCES platform as a specified exercise event.

This legislation was previously published for consultation and has been amended following feedback.

The updated legislation allows existing EMI and CSOP contracts, granted prior to 6 April 2028, to be amended to include a sale on a PISCES platform as a specified exercise event without losing the tax advantages the scheme offers.

This is provided that the new legislative requirements and all other requirements of the schemes are met.

This change will support scaling companies to achieve liquidity and allow their key employees to more easily reap the benefits of EMI and CSOP.

What this means in practice

There will be no change to the way employment related securities are reported to HMRC and there will be no change to the existing EMI or CSOP templates.

Companies are able to amend existing EMI and CSOP contracts that have been granted before 6 April 2028 to allow a sale on a PISCES platform as an exercisable event.

The inclusion of PISCES in existing CSOP or EMI options will be treated as if it had been included in the contract at the time at which the option was originally granted. It will therefore not be treated as a change to the fundamental terms of the option and not cause the loss of associated tax advantages.

Companies must make sure that employees are made aware of the change to include PISCES by either:
- obtaining a written agreement to amend an existing contract
- notifying the employee in writing of the amendment
Further information

Find out more information by reading the technical note: Tax implications for companies and employees in relation to employees trading their shares on PISCES (https://www.gov.uk/government/publications/tax-implications-for-companies-and-employees-in-relation-to-employees-trading-their-shares-on-pisces).

You can also email: xxx@xxx.xx (mailto:xxx@xxx.xx).

Enterprise Management Incentives (EMI) changes

As part of the government’s entrepreneurship package announced at Autumn Budget, 2 changes to EMI schemes are being introduced. These are:
- increases to EMI thresholds
- removal of EMI notification
EMI schemes are targeted share option schemes designed to support small and medium-sized enterprises in recruiting and retaining individual employees. Companies can choose which eligible employees receive options, how many options each selected employee receives, the exercise price and vesting conditions.

EMI threshold change

The government will introduce legislation in the Finance Bill 2025-26 to expand EMI scheme limits from 6 April 2026 to allow more companies to benefit from the tax relief.

What this means in practice

For eligible companies, options granted on or after 6 April 2026 will be subject to the expanded limits:
- the value of company options (from £3 million to £6 million)
- the value of gross assets (from £30 million to £120 million)
- the number of employees (from 250 to 500)
- the maximum holding period (from 10 years to 15 years)
For the first year, there will be no change to the reporting requirements. It will be mandatory for employers to declare their eligibility for the increased thresholds when reporting through the online service from 6 April 2027.

For options granted before 6 April 2026 the original scheme limits will apply.

However, the change in the limit on the exercise period can be applied retrospectively to existing contracts that have not expired or been exercised — provided that these contracts are amended in line with the legislation, the tax advantages will be retained.

There will be no specific change to the reporting requirements relating to the maximum holding period.

Removal of EMI notification

Legislation will be introduced in the Finance Bill 2026-27 to remove the requirement for a company to submit a notification of a grant of EMI options.

The changes will apply to options granted on or after 6 April 2027.

What this means in practice

For options granted on or after 6 April 2027 there will be no requirement for companies to submit a separate notification when granting EMI options.

Instead, HMRC will require the information relating to the grant of options to be included in the EMI end of year returns from 6 April 2028.

Because of this change, companies will need to register a new EMI scheme and make a declaration to confirm the scheme meets the relevant conditions before submitting an end of year return.

Further information

EMI guidance will be updated for 6 April 2026.

To find out more now you can email: xxx@xxx.xx (mailto:xxx@xxx.xx).

Share Incentive Plans (SIP) and Save As You Earn (SAYE) call for evidence summary of responses

At Autumn Budget 2025, the government published the Summary of Responses to the Call for Evidence (CfE) on the SIP and SAYE share schemes.

The CfE was issued under the previous government.

Further information

Find out more about the Non-Discretionary Tax-Advantaged Share Schemes: Call for Evidence (https://www.gov.uk/government/calls-for-evidence/non-discretionary-tax-advantaged-share-schemes-call-for-evidence) or email: xxx@xxx.xx (mailto:xxx@xxx.xx) for more information.