What happened
HMRC's bulletin 69 says that from 28 October 2026 the Company Share Option Plan (CSOP) is also branded "Enterprise Management Incentives 2" (EMI2). HMRC says this reflects its role alongside EMI and as a follow-on scheme for companies that have outgrown EMI. The scheme name stays CSOP in legislation.
What it means for your annual return
- Same template. Bulletin 70 says that when completing a return for CSOP, also known as EMI2, you continue to use the CSOP template.
- Same deadline. The return or nil return is due by 6 July after the end of the tax year. See the 6 July deadline.
- Not an EMI return. EMI2 is CSOP under a new name. Do not put CSOP events on the EMI template.
Which CSOP template to use
| Return for | Filing until 5 April 2027 | Filing from 6 April 2027 |
|---|---|---|
| 2023 to 2024 tax year onwards | Version 5 | Version 7 |
| Before the 2023 to 2024 tax year | Version 4 | Version 6 |
HMRC published the new CSOP versions on 2 November 2026. They cannot be submitted before 6 April 2027, and from that date the older versions are rejected. The sheet names change from CSOP_OptionsGranted_V5, CSOP_OptionsRCL_V5 and CSOP_OptionsExercised_V5 to the same names ending _V7. See the CSOP annual return and HMRC's new templates.
CSOP changes from 6 April 2027
Bulletin 69 also sets out these changes:
- The limit on the value of shares under CSOP options an employee can hold, based on market value at grant, doubles from £60,000 to £120,000.
- CSOP options will no longer count towards the £250,000 EMI individual limit.
- The maximum exercise period rises from 10 years to 15 years for options granted on or after 6 April 2027. Existing option agreements can be amended to use it, provided the amendment is in line with the legislation.
These start on 6 April 2027, which is in the 2027 to 2028 tax year. They do not change how you report events in the 2025 to 2026 or 2026 to 2027 tax years.
Where Share Scheme Return fits
Share Scheme Return checks CSOP data against HMRC's published rules and fills in HMRC's own CSOP template for the 2023 to 2024 tax year onwards. That covers EMI2, because it is the same scheme and the same template. Checking is free.
Questions
What is EMI2?
EMI2 is the new name HMRC uses, from 28 October 2026, for the Company Share Option Plan (CSOP). The scheme name remains CSOP in legislation.
Which template do I use for an EMI2 return?
The CSOP template. HMRC says to continue using the CSOP template when completing a return for CSOP, also known as EMI2.
Is the CSOP limit going up?
Yes, from 6 April 2027 the individual CSOP option limit, based on market value at grant, doubles from £60,000 to £120,000, according to HMRC's bulletin 69.
Based on HMRC's published guidance: ERS bulletin 69 (October 2026). ERS bulletin 70 (November 2026). CSOP end of year template (GOV.UK). Checked on 2 November 2026. This is general guidance, not tax advice, and HMRC's own pages take priority if they change. Share Scheme Return is not affiliated with HMRC.
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