Jurisdiction(s):
United Kingdom

UK HMRC ERS annual return obligations for SIPs and SAYE schemes: registration, deadlines, variations, amendments, penalties, appeals and trustee filing

Published by a LexisNexis Share Incentives expert

Practice notes

For broader guidance on share incentive plans (SIPs), see Practice Note: What is a SIP? For an overview of save as you earn (SAYE) schemes, see Practice Note: How SAYE schemes work and key features.

Legislation governing SIPs and SAYEs—registration and filing requirements

The statutory requirements for SIPs and SAYE schemes are set out in separate schedules to the Income Tax (Earnings and Pensions) Act 2003 (ITEPA 2003): ITEPA 2003, Sch 2 applies to SIPs and ITEPA 2003, Sch 3 applies to SAYE schemes. In this Practice Note, these are termed ‘Schedule 2’ or ‘Schedule 3’, as appropriate—or ‘the applicable schedule of ITEPA 2003’.

The provisions dealing with registration and filing are found as follows:

for SIPs, in ITEPA 2003, Sch 2 Pt 10, paras 81A–81K, and
for SAYE schemes, in ITEPA 2003, Sch 3 Pt 8, paras 40A–45

The HMRC registration process

Before an annual return can be filed with HMRC for a SIP or SAYE scheme, the scheme must first be registered with HMRC as part of HMRC’s online registration...

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Jonathan Fletcher Rogers

Addleshaw Goddard

Jonathan is the head of Addleshaw Goddard's Employee Incentives and Remuneration practice, and advises UK and multinational clients on the design and implementation of share and cash-based employee incentive plans. He also advises quoted companies on corporate governance and disclosure issues in relation to remuneration. Jonathan is a regular speaker at conferences on executive remuneration and share plans more generally and has been recognised as a leading individual in employee incentives in Chambers and Partners....

Web page updated on 22/05/2026

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