Updated 18/09/2026: Further guidance published from HMRC on 17 September 2026
This article has been updated to reflect guidance published, and further information provided by HMRC on 17 September 2026. The updates are clearly marked below.
Key takeaways
- New reporting requirements: directors must complete additional boxes on the 2025/26 tax return.
- Unpaid directors: the requirements apply regardless of whether the director is paid by the company, but do not apply to unpaid directors of charities.
- Multiple directorships: the software issue limiting the number of employment pages that may be filed remains, despite clarification from HMRC on charities.
In an article published in May 2026, ICAEW’s Tax Faculty highlighted potential issues reported by members in complying with the new SA requirements for directors of close companies for 2025/26 onwards. Briefly, directors must now complete the following boxes on the employment pages (SA102) of the tax return:
- box 6 (was the person a director of the company); and
- depending on their circumstances, boxes 7 to 7.4 (the close company boxes).
We raised the members’ issues with HMRC and have now received a response, as summarised below.
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This audio file was produced by AI and has been adapted from the original article for audio purposes.
Unpaid directors
HMRC has confirmed to ICAEW that unpaid directors – ie, directors receiving no remuneration or dividends – must complete the close company boxes on the tax return. An exception has been introduced for unpaid directors of charities and community interest companies (CIC) (see under Multiple directorships below).
The statutory basis for HMRC’s response would appear to be regulations 5(b) and 5(c) of the Income Tax (Additional Information to be included in Returns) Regulations 2025 (SI 2025/84). The regulations provide that dividend and shareholding information must be provided, including if the relevant figures are “zero”. Where zero dividend income (box 7.3) and/or a zero shareholding (box 7.4) is to be reported, “0” (zero) should be entered in the appropriate box or boxes, rather than leaving the box or boxes blank. Leaving a box blank is a cause of some filing errors.
HMRC has also informed ICAEW that listing unpaid directorships in the additional information (white space) section of the SA tax return is not an acceptable option. However, see under Multiple directorships, below, for a possible exception to this.
HMRC may charge a £60 penalty where a taxpayer does not comply with the requirement to complete the close company boxes, regardless of the number of directorships, missing employment pages or incomplete boxes (s8(1K), Taxes Management Act 1970).
Update: 17 September 2026
HMRC has published further guidance on this area in issue of 147 of agent update. HMRC states that it will “take a considered approach” when assessing compliance with the new requirements, taking into account “all relevant facts and circumstances, including the reasonable efforts customers have made to meet their obligations in light of the information and guidance available to them at the time.”
Dormant companies
HMRC has advised ICAEW that directors of dormant close companies must complete the close company boxes.
Multiple directorships
It has been reported that some software packages set a limit (typically eight) on the number of employment pages that can be filed as part of a SA tax return.
On 8 September 2026, HMRC updated page two of the SA tax return notes (SA150) to clarify that directors of a registered charity or CIC do not need to complete the close company boxes where they “did not receive, and did not become entitled to receive, any employment income or dividend income, including any other type of distribution from that company or any connected company”.
Although this clarification is welcome, it does not solve the problem for individuals with multiple directorships in non-charitable, close companies, such as family companies, groups or those in the private equity sector. We have asked HMRC to consider providing a solution in such cases.
Update: 17 September 2026
ICAEW understands that HMRC’s online reporting system has been updated to include the following advice: “You should complete a separate employment page for each employment or directorship wherever possible: Where the number of employment and directorships exceeds the number of employment pages available, you should use the available employment pages first for employments and directorships that require completion of employment income, benefits, expenses or other employment-related entries, before using the ‘Any other information’ section to provide details of any remaining directorships.”
Other issues
It should be noted that:
- the new requirements only apply to a director who is already required to complete a tax return. Directors who are not within SA do not have to register just to report close company information; and
- the director must complete the close company boxes if the company is close for any part of the tax year.
To contact the faculty about the issues discussed above, or related issues, please email Katherine Ford.
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