It is important to register all of your schemes – or any arrangements relating to the acquisition of shares by employees, whether a “scheme”, a bespoke arrangement for one or more employees or directors, or otherwise – in advance of the 6 July 2015 deadline, or else there may be serious consequences.

CSOP, SIP and SAYE

It is essential that all of these schemes are registered before 6 July or else they will lose their tax-advantaged status in relation to all options and awards granted in the 2014-15 tax year and going forward.

For CSOPs, this will also apply retrospectively – if a CSOP is not registered by 6 July 2015, all options granted under it will lose their tax-advantaged status, even if granted before 6 April 2014.

Other schemes and arrangements

If a “reportable event” involving employment-related securities has occurred in the 2014-15 tax year, you must file an annual return (the online Form 42) by 6 July 2015 or else penalties will apply. “Reportable event” is broadly defined and you should seek advice if you are at all uncertain about whether a report needs to be made.

In order to file a return, you must register the unapproved scheme or arrangement before the 6 July deadline as this is an absolute cut-off. Failure to register may mean that you are unable to file your annual return for 2014/15.

For EMI options which have already been registered using the new online arrangements, or earlier under the old paper based system, there is also a separate online annual reporting requirement before 6 July 2015 that replaces the paper Form 40.

If you require any guidance or information on the registration process, please contact us and we will be happy to provide assistance.