Following the publication of our FAQ guide on the additional information requirements for self-assessment tax returns for directors, the ATT has continued to engage with HMRC to seek clarification on how the requirements are intended to operate in practice, and to address the inconsistencies between HMRC's published guidance and the legislation. 

From the 2025/26 tax year onwards, directors who are required to submit a Self Assessment tax return must provide additional information through the SA102 employment pages. Our previous Employer Focus article explained the new requirements in more detail. Since then, HMRC have provided further clarification on a number of the requirements. Our updated FAQ guide reflects our understanding of HMRC's current interpretation of the requirements. While it provides clarification in several areas, some important questions remain unanswered. 

Scope of the requirements 

It is worth noting that the definitions of “company” and “director” are broad. For example, a company includes unincorporated associations, and a director includes any person occupying the position of director, even if they have not been formally appointed. As a result, the additional information requirement may apply in circumstances where this is not immediately obvious or expected. For more information on these points, please see our FAQ guide.

A separate SA102 is expected for each directorship

HMRC have confirmed that a separate SA102 is expected to be completed for every directorship, even where no salary, benefits or dividends have been received. 

However, this position is not yet reflected in HMRC's published guidance, which currently suggests employment pages are only required where income or benefits have been received from a directorship. HMRC have indicated that they plan to update this guidance.

What about directors of dormant companies? 

HMRC have also confirmed that directors of dormant companies are within the scope of the new requirements.

Although a dormant company may have had no activity, and the director may not have received income or benefits from that company, directors must still complete a SA102 and provide the additional information if they are otherwise required to submit a tax return. This may create practical challenges, as taxpayers do not always tell their advisers about dormant companies.

Directors who do not need to complete a tax return for any other reason will not be required to register for self-assessment to deal with this new requirement.

Penalties

Failure to comply will result in a £60 penalty. HMRC consider the additional information requirements to be a single composite requirement, meaning only one £60 penalty should apply to a tax return, regardless of the number of directorships, close companies or individual omissions. 

While this clarification is welcome, the ATT continues to encourage HMRC to adopt a soft-landing approach during the first year until compressive guidance has been issued. 

What questions remain? 

There remain a number of areas of uncertainty and, in some cases, HMRC's published guidance does not align with the wording of the legislation. Our FAQ guide covers these issues in more detail.

In addition, software issues are beginning to emerge, including how shareholdings should be reported where software rounds percentages, and limitations on the number of SA102 employment pages that some software products can accommodate. These issues have also been raised with HMRC.

The ATT is continuing to seek clarification from HMRC on a number of points. If you have any additional questions that are not covered in the FAQ guide, please email [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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