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.
HMRC's guidance on the new additional information requirements is limited. This FAQs guide reflects the ATT's understanding of HMRC's interpretation as at the date of publication. You may wish to check against available legislation and any official guidance on GOV.UK that that position has not changed.
In some areas, HMRC’s interpretation does not fully align with the wording of the legislation. We have sought clarification from HMRC on these points and will update the FAQs as further guidance or clarification is received.
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.
- 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).
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 page) for each directorship.
You cannot provide this information in a single white space disclosure listing multiple directorships.
Note: HMRC's published guidance is currently limited. The SA102 Employment notes and SA150 Tax Return notes both suggest that the SA102 Employment pages only need to be completed where income is received from a directorship. However, the legislation imposes the additional information requirements on all directors who are required to submit a tax return, regardless of whether they receive income from that directorship.
We have queried this point with HMRC, who have confirmed that the additional information should be provided in the SA102 Employment pages (and not in the white space on the return), even where no income is received from the directorship. HMRC is seeking to update its guidance contained within the SA102 Employment notes and SA150 Tax Return notes.
While the legislation requires the additional information to be included in the tax return, it does not prescribe a specific format or place in the return. HMRC has nevertheless confirmed that it expects a separate SA102 Employment page to be completed for each directorship.
Yes.
A penalty of £60 may apply if you fail to provide the required additional information. (see “What additional information do I need to include in my tax return if I’m a director of a company?”).
HMRC has indicated to us that, for these purposes, the additional information requirements for directors (Regulations 3, 4, and 5 SI 2025/84) are treated as a single composite requirement.
As a result, HMRC's view is that only one £60 penalty can arise in relation to a tax return for failure to comply with the additional information requirements. This applies regardless of:
- how many directorships are involved;
- how many close companies are involved; or
- how many items of required additional information (for example, name of the close company, company registration number, dividend income or percentage shareholding) are omitted.
In particular:
- a separate penalty does not arise for each directorship; and
- a separate penalty does not arise for each missing item of information (for example, the company name, company registration number, dividend income or percentage shareholding).
Example
Chris is a director of four close companies and is required to provide the additional information for each directorship.
- If he fails to provide the information for one of the companies, a single £60 penalty may apply.
- If he fails to provide the information for all four companies, a single £60 penalty may apply.
- If he provides all of the required information except his percentage shareholding for one of the companies, a single £60 penalty may apply.
Note: Given the uncertainty surrounding HMRC's interpretation of the additional information requirements, the wording of SI 2025/84 and HMRC's guidance (as discussed throughout this FAQ guide), we have asked HMRC to consider adopting a soft-landing approach while further clarification is sought. At the time of writing, HMRC has not confirmed whether a soft-landing approach will be adopted.
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 nominal 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 are 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?”).
Note: HMRC's published guidance is currently limited. The SA102 Employment notes and SA150 Tax Return notes both suggest that the SA102 Employment pages only need to be completed where income is received from a directorship. However, the legislation imposes the additional information requirements on all directors who are required to submit a tax return, regardless of whether they receive income from that directorship.
We have queried this point with HMRC, who have confirmed that the additional information should be provided in the SA102 Employment pages (and not in the white space on the return), even where no income is received from the directorship. HMRC is seeking to update its guidance contained within the SA102 Employment notes and SA150 Tax Return notes.
While the legislation requires the additional information to be included in the tax return, it does not prescribe a specific format or place in the return. HMRC has nevertheless confirmed that it expects a separate SA102 Employment page to be completed for each directorship.
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?”).
Note: HMRC's published guidance is currently limited. The SA102 Employment notes and SA150 Tax Return notes both suggest that the SA102 Employment pages only need to be completed where income is received from a directorship. However, the legislation imposes the additional information requirements on all directors who are required to submit a tax return, regardless of whether they receive income from that directorship.
We have queried this point with HMRC, who have confirmed that the additional information should be provided in the SA102 Employment pages (and not in the white space on the return), even where no income is received from the directorship. HMRC is seeking to update its guidance contained within the SA102 Employment notes and SA150 Tax Return notes.
While the legislation requires the additional information to be included in the tax return, it does not prescribe a specific format or place in the return. HMRC has nevertheless confirmed that it expects a separate SA102 Employment page to be completed for each directorship.
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?”).
This means that even if you do not receive any employment income, benefits, or dividends, you are still expected to complete an SA102.
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?”).
Note: HMRC's published guidance is currently limited. The SA102 Employment notes and SA150 Tax Return notes both suggest that the SA102 Employment pages only need to be completed where income is received from a directorship. However, the legislation imposes the additional information requirements on all directors who are required to submit a tax return, regardless of whether they receive income from that directorship.
We have queried this point with HMRC, who have confirmed that the additional information should be provided in the SA102 Employment pages (and not in the white space on the return), even where no income is received from the directorship. HMRC is seeking to update its guidance contained within the SA102 Employment notes and SA150 Tax Return notes.
While the legislation requires the additional information to be included in the tax return, it does not prescribe a specific format or place in the return. HMRC has nevertheless confirmed that it expects a separate SA102 Employment page to be completed for each directorship.
Yes.
You are still required to provide the additional information (see “What additional information do I need to include in my tax return if I’m a director of a company?”).
HMRC has confirmed to us that the additional requirements apply to directors of dormant companies. The fact that a company is dormant does not remove the obligation to provide the additional information.
Note: HMRC's published guidance is currently limited. The SA102 Employment notes and SA150 Tax Return notes both suggest that the SA102 Employment pages only need to be completed where income is received from a directorship. However, the legislation imposes the additional information requirements on all directors who are required to submit a tax return, regardless of whether they receive income from that directorship.
We have queried this point with HMRC, who have confirmed that the additional information should be provided in the SA102 Employment pages (and not in the white space on the return), even where no income is received from the directorship. HMRC is seeking to update its guidance contained within the SA102 Employment notes and SA150 Tax Return notes.
While the legislation requires the additional information to be included in the tax return, it does not prescribe a specific format or place in the return. HMRC has nevertheless confirmed that it expects a separate SA102 Employment page to be completed for each directorship.
If a company becomes a close company part-way through the tax year, the additional information requirements apply in relation to the period during which the company is a close company.
HMRC has confirmed that dividends received before the company became a close company should not be included in Box 7.3 (dividend income received from the close company).
Please note that dividends received before the company becomes a close company would however remain reportable as part of the overall declaration of dividend income in the SA100 return.
Example
David is a director of ABC Ltd throughout the 2025/26 tax year. ABC Ltd is not a close company at the start of the tax year but becomes a close company on 1 January 2026.
David receives:
- a dividend of £5,000 on 1 June 2025; and
- a dividend of £3,000 on 1 February 2026.
David would be required to provide the additional information (see “What additional information do I need to include in my tax return if I’m a director of a company?”).
However, only the £3,000 dividend received after ABC Ltd became a close company, on 1 January 2026, should be included in Box 7.3.
Both dividends (£8,000 in total) should be included in David's total dividend income reported on the SA100.
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.
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 such 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.
Note: The SA102 notes indicate that company secretaries are only required to complete employment pages where they receive income in that capacity. However, HMRC has confirmed that where a company secretary performs functions that fall within the definition of a director in section 250 of the Companies Act 2006, they would be regarded as a director for the purposes of SI 2025/84. In those circumstances, they would be expected to comply with the additional information requirements. 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.