31 March 2026: Share Scheme Reporting Deadline for Employers and Trustees
The annual deadline for employers and trustees to report share scheme activity to Revenue is fast approaching. All share scheme transactions during 2025 must be reported by 31 March 2026.
Reporting Obligations
Form ESA
Share incentive: Restricted Stock Units, Discounted or Free Shares, Restricted Shares, Convertible Securities, Forfeitable Shares, Growth Shares, Hurdle Shares, Phantom Shares, Stock Appreciation Rights and any other award with a cash payment equivalent to shares.
Reportable events: The award of shares, or the award of cash payments based on the value of shares. The reporting of the grant of Restricted Stock Units remains optional.
How to file: Online through ROS.
Form RSS1
Share incentive: Share options and other rights.
Reportable Events: The grant, exercise, assignment and/or release of the options.
How to file: Online through ROS.
Form KEEP1
Share incentive: Key Employee Engagement Programme ('KEEP') options.
Reportable Events: The grant, exercise, assignment and/or release of the options.
How to file: Online through ROS.
Form ESS1
Share incentive: Approved Profit Share Schemes ('APSS').
Reportable Events: Details of shares appropriated, disposed and transferred, as well as capital receipts by the trustees. A NIL return should be filed if there has been no activity.
How to file: Online through ROS.
Form SRSO1
Share incentive: Save As You Earn ('SAYE').
Reportable Events: The grant and exercise of the options. A NIL return should be filed if there has been no activity.
How to file: Paper filing.
Form ESOT1
Share incentive: Employee Share Ownership Trusts.
Reportable Events: Details of the funds received by the trustees and the acquisition, sale and transfer of shares. A NIL return should be filed if there has been no activity.
How to file: Paper filing.
Failure to Comply
Non-compliance can trigger financial penalties, withdrawal of approval for tax-efficient schemes like an APSS or SAYE, or Revenue compliance interventions. Share schemes have been subject to strict scrutiny from Revenue in the past few years. In 2024 alone, 449 compliance interventions relating to share schemes were concluded.
Act Now
Employers and trustees should now review their 2025 share scheme activity and prepare the relevant reporting return. The share scheme reporting data should also be reconciled against payroll data to ensure that PAYE, PRSI and USC was correctly withheld and remitted on the share awards (where applicable). This is also a good opportunity to consider whether the share scheme remains aligned with business goals and continues to deliver value to the company, employees and directors.
How we can help
McCann FitzGerald LLP provides expert advice on the establishment and implementation of share schemes. We can also help businesses prepare and file the relevant share scheme reporting returns. 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.
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