31 March 2026: Share Scheme Reporting Deadline for Employers and Trustees

The annual deadline for employers and trustees to report share scheme activity to Revenue is fast approaching. All share scheme transactions during 2025 must be reported by 31 March 2026.

Reporting Obligations

Form ESA

·       Share incentive: Restricted Stock Units, Discounted or Free Shares, Restricted Shares, Convertible Securities, Forfeitable Shares, Growth Shares, Hurdle Shares, Phantom Shares, Stock Appreciation Rights and any other award with a cash payment equivalent to shares.

·       Reportable events: The award of shares, or the award of cash payments based on the value of shares. The reporting of the grant of Restricted Stock Units remains optional.

·       How to file: Online through ROS.

Form RSS1

·       Share incentive: Share options and other rights.

·       Reportable Events: The grant, exercise, assignment and/or release of the options.

·       How to file: Online through ROS.

Form KEEP1

·       Share incentive: Key Employee Engagement Programme ('KEEP') options.

·       Reportable Events: The grant, exercise, assignment and/or release of the options.

·       How to file: Online through ROS.

Form ESS1

·       Share incentive: Approved Profit Share Schemes ('APSS').

·       Reportable Events: Details of shares appropriated, disposed and transferred, as well as capital receipts by the trustees. A NIL return should be filed if there has been no activity.

·       How to file: Online through ROS.

Form SRSO1

·       Share incentive: Save As You Earn ('SAYE').

·       Reportable Events: The grant and exercise of the options. A NIL return should be filed if there has been no activity.

·       How to file: Paper filing.

Form ESOT1

·       Share incentive: Employee Share Ownership Trusts.

·       Reportable Events: Details of the funds received by the trustees and the acquisition, sale and transfer of shares. A NIL return should be filed if there has been no activity.

·       How to file: Paper filing.

Failure to Comply

Non-compliance can trigger financial penalties, withdrawal of approval for tax-efficient schemes like an APSS or SAYE, or Revenue compliance interventions. Share schemes have been subject to strict scrutiny from Revenue in the past few years. In 2024 alone, 449 compliance interventions relating to share schemes were concluded.