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Changes made to new self-assessment information requirements for directors

For 2025/26 onwards, directors who are required to submit a tax return must generally provide additional information about each directorship they hold. Despite the broad drafting of the regulations, HMRC have clarified that exceptions apply in certain circumstances.

Our updated FAQ guide reflects HMRC's latest guidance and correspondence with the ATT, including clarification of situations where directors may not be required to provide this additional information. 

Directors of non-UK companies

HMRC's recently updated SA102 Employment notes and SA150 Tax Return notes state that directors of non-UK companies are only required to provide the additional information if their directorship is “with pay or benefits”. 

This means that directors of non-UK companies who receive neither pay nor benefits will not normally be required to complete an SA102 in respect of that directorship.

While this relaxation is welcome, questions remain. Among other things, we have asked HMRC to confirm whether “with pay or benefits” applies only where the individual receives employment income that is taxable in the UK for the relevant tax year.

For more information about the points on which we are seeking clarification from HMRC, see “Do I need to report additional information if I am a director of a non-UK company?” in our FAQ guide. 

Charities and community interest companies

HMRC’s updated guidance also states that directors of registered charities and community interest companies (CICs) do not need to provide the additional information where they neither receive nor become entitled to receive employment income, dividend income or any other distribution from the company or a connected company. 

Again, while this relaxation is welcome, questions remain. Among other things, we have asked HMRC to confirm whether this treatment applies to equivalent overseas organisations and where, for example, employment income is received what registration number should be entered in box 7.2.

For more information about the points on which we are seeking clarification from HMRC, see “Do I need to report the additional information if I am a director of a registered charity or community interest company?” and “Do I need to report additional information if I am a director of an unincorporated association?” in our FAQ guide.

What questions remain?

Our updated FAQ guide identifies the outstanding matters on which we are seeking further clarification from HMRC.

We will continue to engage with HMRC update our FAQ guide as further clarification becomes available. If you have encountered issues or have questions that are not covered by our guidance, please contact [email protected].

 

This article reflects the position at the date of publication shown above. If you are reading this at a later date you are advised to check that that position has not changed in the time since.   

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