ATT updates FAQ guide on 2025/26 additional information requirements for directors
The ATT has updated its FAQ guide on the additional information requirements for directors completing their self-assessment tax returns to reflect both HMRC's current interpretation of the requirements and ongoing areas of uncertainty in the regulations and their practical application.
Directors who are otherwise required to submit a personal tax return for 2025/26, and subsequent tax years, must now provide additional information for each directorship through the SA102 Employment pages.
However, HMRC has recognised that applying the requirements in full could create an unnecessary administrative burden in circumstances where the information is unlikely to be useful for tax administration. HMRC has therefore decided to use its Care and Management powers to introduce limited exceptions for the new requirements for certain directors of non-UK companies, registered charities and community interest companies (CICs). The exceptions are welcome, but they are very limited and are not expressly set out in the regulations. It is unfortunate that their scope is also unclear, leaving directors and advisers with important questions about when and how they apply.
HMRC recently updated its updated SA102 Employment notes and SA150 Tax Return notes to reflect these limited exceptions. HMRC's guidance on the new additional information requirements remains limited, and the FAQ guide reflects the ATT's understanding of HMRC's interpretation as at the date of publication.
If you have any additional questions not covered in the FAQ guide, please email [email protected]. We are also actively seeking clarification from HMRC on several points and will update guidance as further information becomes available.