HMRC have released Employment-Related Securities (ERS) Bulletin 62. It contains details from Autumn Budget 2025, including on the 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.
You can see our detailed Autumn Budget coverage here: Employment Taxes: Autumn Budget 2025
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. It is designed to support private companies to scale in size and growth.
- 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 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.
The 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 access liquidity and allow their key employees to more easily reap the benefits of EMI and CSOP.
There will be no change to the way ERS 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 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 not be treated as a change to the fundamental terms of the option and will 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.
Enterprise Management Incentives (EMI) changes
As part of the government's entrepreneurship package announced at Autumn Budget, two changes to EMI schemes are being introduced. These are:
- Increases to EMI thresholds.
- Removal of EMI notification.
The government will introduce legislation in Finance Bill 2025-26 to expand EMI scheme limits from 6 April 2026 to allow more companies to benefit from the tax relief.
- For eligible companies, options granted on or after 6 April 2026 will be subject to the expanded limits:
- The value of company options: £6 million (from £3 million).
- The value of gross assets: £120 million (from £30 million).
- The number of employees: 500 (from 250).
- The maximum holding period: 15 years (from 10 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.
- 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 legislation, the tax advantages will be retained.
- There will be no specific change to the reporting requirements relating to the maximum holding period.
Legislation will be introduced in 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.
- 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.
- 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.
- HMRC will update their guidance for 6 April 2026.
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 on the SIP and SAYE share schemes.
See Non-Discretionary Tax-Advantaged Share Schemes consultation responses
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