Starting 18 March 2026, the SEC will require non-US Foreign Private Issuers (FPIs) to comply with new Section 16(a) insider reporting rules under the Holding Foreign Insiders Accountable Act. However, on 5 March 2026, the SEC granted exemptive relief for certain jurisdictions, delaying full application of the rules.

On 18 March 2026, the European Commission proposed “EU Inc.”, a new optional EU-wide corporate structure designed to simplify cross-border operations, boost competitiveness, and support startup growth through a harmonised set of corporate rules. A key feature is the introduction of EU employee stock option plans (EU-ESOs), which would allow companies to grant portable stock options across EU member states and defer taxation until the shares are sold, helping employees avoid “dry tax” on unrealised gains. The proposal would significantly change the treatment of share options in countries like Ireland by aligning EU-ESOs more closely with Ireland’s Key Employee Engagement Programme, and it is now under review by the European Parliament and Council with a target agreement date by the end of 2026.

The Netherlands is proposing new tax incentives to support startups and scale-ups, including a favorable employee stock option regime where only 65% of benefits are taxed and tax is deferred until shares are sold. It also introduces a clearer definition of startups for tax purposes to improve access to talent and investment. To fund this, existing entrepreneur tax deductions will be reduced in 2027 and abolished by 2030.

At Budget 2025, the UK government announced major expansions to the Enterprise Management Incentives (EMI) scheme from 6 April 2026, increasing the employee limit to 500, gross assets to £120m, and the company-wide option limit to £6m, making EMI available to more scale-ups. The maximum EMI option exercise period is extended from 10 to 15 years, with the change intended to apply retrospectively to existing options, and EMI/CSOP rules will also allow PISCES platform sales as a valid exercise event. These updates, along with earlier implementation timelines starting from 2025 for PISCES-related changes, aim to improve liquidity options and broaden access to tax-advantaged employee equity schemes.

UK employee share schemes are a key tool for attracting and retaining talent, especially in scale-ups, with four main HMRC tax-advantaged options: EMI, CSOP, SAYE, and SIP. From April 2026, EMI is significantly expanded, increasing company size limits, asset thresholds, employee caps, and option lifetimes, making it accessible to many more businesses and still offering the most generous tax treatment (capital gains rather than income tax). Each scheme serves different needs—from EMI for scale-ups, CSOP for larger or ineligible firms, SAYE and SIP for all-employee participation—while non-tax-advantaged options like growth shares are used when HMRC schemes don’t fit but require more careful tax structuring.

This HMRC helpsheet explains how employee share schemes and share options are treated for Capital Gains Tax, covering approved schemes (like SIP, SAYE, CSOP, EMI) and unapproved arrangements. In general, your CGT cost is what you paid for the shares plus any amount already taxed as employment income, with special rules for different schemes (for example, SIP shares can be CGT-free if held correctly, and EMI options get favourable treatment including from grant date for relief purposes). It also sets out administrative rules such as reporting requirements, elections (like same-day share acquisition elections), transfers to ISAs or pensions, and reliefs for certain disposals, all of which affect how and when tax is calculated on employee-related shares.

Employers must report all 2025/26 employment-related securities activity to HM Revenue & Customs by 6 July 2026, including registering new share plans, filing annual or nil returns, and ensuring complete and accurate disclosures to avoid automatic penalties. Reporting is especially complex for areas such as internationally mobile employees, net-settled awards, and corporate transactions, which require careful coordination across payroll, tax, legal, and HR teams. Employers should review all share plan activity now to confirm compliance, align reporting with payroll and corporation tax records, and address any issues before the filing deadline.

Companies with UK employees participating in share plans must complete their annual Employment Related Securities (ERS) reporting with HM Revenue & Customs by 6 July 2026 to avoid penalties and maintain compliance. Employers must register new plans, file annual or nil returns for all registered schemes, and self-certify tax-advantaged plans such as SIP, SAYE, and CSOP while ensuring accurate reporting of all relevant share-related events. Missing deadlines or making common filing errors can lead to escalating fines and the loss of valuable tax advantages for both employers and employees.

Artificial intelligence is reshaping modern businesses by concentrating value creation in a smaller number of highly skilled individuals, making employee alignment and retention more important than ever. Employee Share Option Schemes (ESOPs) allow companies to grant selected employees the right to acquire shares over time, with their success depending on careful legal structuring around vesting, governance, and participation terms. Cyprus has strengthened ESOP incentives through its 2026 tax reform, introducing an 8% flat tax rate for approved schemes that meet specific conditions, with companies able to use a transitional approval period until 30 June 2026 to benefit from the new regime.