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knowledge 26 February 2024 |

Employer Share Scheme Reporting - 31 March 2024 Filing Deadline

The deadline for annual share scheme reporting is fast approaching. 31 March 2024 is the mandatory filing deadline for employer returns of information in relation to employee share incentive schemes operated in 2023. Employers may be subject to financial penalties if they fail to comply with their reporting obligations.

What needs to be reported

Employers need to report:

  • Form RSS1 – The grant of unapproved share options to directors and employees in 2023, as well as the exercise, assignment and/or release of unapproved share options by directors and employees in 2023.
  • Form KEEP1 - The grant of options under the Key Employee Engagement Programme (‘KEEP’) to directors and employees in 2023, as well as the exercise, assignment and/or release of KEEP options by directors and employees in 2023.
  • Form ESA - The award of restricted stock units, restricted shares, convertible shares, forfeitable shares, discounted/free/matching shares, phantom shares, stock appreciation rights, growth shares, cash awards whose value is based on share value and any other share awards not captured under other reporting requirements.

The same filing deadline for returns of information also applies to Revenue-approved share incentive schemes; Approved Profit Sharing Schemes (Form ESS1), Save As You Earn Schemes (Form SRSO1) and Employee Share Ownership Trusts (Form ESOT1).

Next Steps

Employers must now review their share incentive activity during 2023 and prepare the relevant reporting return. Employers must also ensure that they are registered for Share Scheme Reporting prior to submitting any returns to Revenue.

Compliance Reviews

As share-based remuneration is an increasingly popular tool used to reward employees, Revenue have upped their compliance oversight of share incentives schemes. Revenue frequently carry out compliance interventions to ensure that both employers and employees are adhering to their tax obligations.

How we can help

McCann FitzGerald LLP provides expert advice on the establishment, implementation and tax reporting of share incentive schemes. If you would like to discuss your return filing obligation in relation to existing schemes, please contact the team below or your usual McCann FitzGerald LLP contact for further information.

This document has been prepared by McCann FitzGerald LLP for general guidance only and should not be regarded as a substitute for professional advice. Such advice should always be taken before acting on any of the matters discussed.