Image of person typing on laptop

Tax return changes (2025/26): What directors need to know

From the 2025/26 tax year onwards, directors must provide additional information in their tax returns.

These requirements are set out in Statutory Instrument 2025/84, The Income Tax (Additional Information to be included in Returns) Regulations 2025.

Below is a list of Frequently Asked Questions (FAQs), to help taxpayers and agents understand the additional information requirements and what it will mean for them. 

The information presented on this page represents the ATT’s understanding based on the information available at the date of publication shown. You may wish to check against available legislation and any official guidance on GOV.UK that that position has not changed.

Frequently Asked Questions

From the 2025/26 tax year onwards, directors must provide additional information in their tax returns. 

When completing the SA102 (employment pages), you must include the following additional information:

Director and company status: 

  • Whether you were a director during the tax year (box 6), and 
  • If so, whether the company is a close company (box 7)

You must provide this information for each of your directorships. For 2024/25 and earlier tax years, these boxes were included in the SA102, but completion was not mandatory.

Close company details:

Where you are a director of a close company, you must also provide the following additional information: 

  • The name of the close company (box 7.1);
  • The company registration number (box 7.2);
  • The dividend income you received from that close company (box 7.3)
    • you must include this even if the amount is zero, 
    • this should be the same type of income that you include in box 4 of page TR3 on the SA100 (main tax return).
  • The total percentage of the share capital held in the company (See "How do I calculate my percentage shareholding?") (box 7.4), 
    • you must include this even if the percentage is zero. 

These boxes (7.1 to 7.4) are new for the 2025/26 tax year onwards and a separate SA102 must be completed for each close company you are a director of.

Boxes 7.1 to 7.4 are only required where you are a director of a close company. If you are a director of a company that is not a close company, these boxes do not need to be completed, even if you own shares in the company. You are however still expected to complete boxes 6 and 7 (see above).

Yes.

You must provide the additional information if you were a director of a company at any point during the tax year, even if you resigned or ceased to be a director before the end of the tax year.

This includes cases where:

  • you were appointed and resigned within the same tax year; or
  • you ceased to be a director part way through the tax year.

Please see “What additional information do I need to include in my tax return if I’m a director of a company?” for details of the additional information required.

No.

HMRC no longer expect all company directors to complete a tax return and the new requirements do not create a separate obligation to file a tax return. 

You only need to provide the additional information if you are already required to file a personal tax return for the 2025/26 tax year (or later tax year), whether under Making Tax Digital for Income Tax or ’classic’ Self Assessment.

Yes, you must complete a separate SA102 (employment pages) for each directorship.

You cannot provide this information in a single white space disclosure listing multiple directorships.

Yes. 

A penalty of £60 may apply for each failure to provide the required information.

It is currently unclear how HMRC will apply this in practice and whether this will be:

  • A single penalty per tax year, or
  • Multiple penalties (for example, per directorship or per missing item)

Further clarification has been sought from HMRC on this point.

HMRC’s Employment notes for 2025/26 state that:

“The Percentage shareholding in the close company is the total percentage of the share capital owned. This should be calculated by reference to the nominal value of the shares.” 

Example:

Sam owns 5,000 £1 ordinary shares in Cars Ltd. If Cars Ltd has a total of 10,000 £1 ordinary shares in issue, Sam’s percentage shareholding is 50% (5,000/10,000 × 100) of the nominal share capital.

Note: The relevant legislation refers to share capital “held”. Clarification has been requested from HMRC, to confirm that the share capital should be the percentage owned. 

You should report the highest percentage owned during the tax year.

For example, if your percentage shareholding decreases from 60% to 50% during the tax year, you should report 60%, being the highest percentage owned.

Companies may have multiple share classes with different nominal values.

The percentage shareholding is based on the total nominal value of shares held compared to total nominal value of the issued share capital.

Example: Laura is a director and shareholder in Music Ltd. 

Laura owns 

  • 100 £1 A ordinary shares (£100) 
  • 40,000 £0.01 B ordinary shares (£400)

The total nominal value of Laura’s shares is £500 (£100 + £400). 

Music Ltd has issued: 

  • 200 £1 A ordinary shares (£200)
  • 80,000 £0.01 B ordinary shares (£800)

The total nominal value of share capital in Music Ltd is £1,000

Laura’s percentage of nominal share capital is 50% (500/1000). 

All share capital should be included when calculating the percentage, regardless of rights attached. This includes shares described as:

  • Preference  
  • Non-voting  
  • Redeemable  
  • Cumulative  
  • Convertible  

“Ordinary share capital” excludes shares with a fixed dividend and no further rights to profits.

However, for this requirement, the legislation refers to share capital, meaning all issued share capital should be considered.

You are still required to provide the additional information if you are a director of a close company (see “What additional information do I need to include in my tax return if I’m a director of a company?”).

Even if you do not hold any shares, you must enter zero in:

  • Box 7.3 – dividend income received from the close company
  • Box 7.4 – percentage of share capital held

If either of these boxes is left blank, you could be treated as having failed to provide the required additional information and may be subject to a penalty (see “Are there penalties for failing to provide the information?”).

You are still required to provide all of the additional information (see “What additional information do I need to include in my tax return if I’m a director of a company?”).

You must enter zero in Box 7.3 – dividend income received from the close company.

If this box is left blank, you could be treated as having failed to provide the required additional information and may be subject to a penalty (see “Are there penalties for failing to provide the information?”).

It depends.

The additional information requirements apply to “directors”. Under section 250 of the Companies Act 2006, a director includes any person occupying the position of director, even if not formally appointed.

This means that de facto directors (also known as “shadow directors”) may be treated as directors and subject to the same additional information requirements. 

Officers of a company (such as a company secretary) are not automatically included. However, if an officer is in reality performing functions or making decisions that are typically the responsibility of a director, they may be treated as a de facto director and therefore fall within the scope of the requirements.