Employers who operate an ERS scheme must submit an annual return to HMRC. The deadline for submitting the return for 2025/26 is by 6 July 2026.
In an update to its guidance at ERSM 140030, HMRC has announced that, with effect for all previous and future tax years, employers are no longer required to report non-tax advantaged ERS data where:
- the employee is an STBV who is covered by an EP Appendix 4 arrangement;
- and no UK income tax or NIC would be due.
ICAEW’s Tax Faculty welcomes this announcement, having called for it through its Employment Taxes Committee since HMRC first confirmed its position on this issue on 10 July 2025.
ICAEW believes that HMRC’s revised guidance is consistent with how employers were applying the rules prior to 10 July 2025, simplifying ERS reporting for employers. It is thought that HMRC’s change in approach is unlikely to cause any issues for employers as most would have already filed their 2024-25 ERS return at the point that HMRC published its initial guidance.
HMRC announcement on ERS and STBV follows the announcement in January 2026 of a separate ERS relaxation to the net settlement reporting requirement.
ICAEW’s Employment Taxes Committee
The Tax Faculty is ICAEW’s voice for tax. The work of its technical staff is supported by the active members (also known as volunteers) on its committees and sub-committees. To find out more about the committees, including how to join, please see the contacts page.
Further information
Prepare for 2026/27 series
ICAEW's Tax Faculty looks at the key tax changes applying from April 2026.
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ICAEW's Tax Faculty is recognised internationally as a leading authority and source of expertise on taxation. The faculty is the voice of tax for ICAEW, responsible for all submissions to the tax authorities. Join the Faculty for expert guidance and support enabling you to provide the best advice on tax to your clients or business.