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Employers are obligated to report certain share scheme benefits provided to employees and submit the annual return to Revenue by the 31 March 2026. The transactions to be reported would be in relation to the tax year 2025.
You will likely have a requirement to file by 31 March 2026 if:
- Irish directors, employees, or foreign employees with Irish work duties have acquired shares or other securities in your company.
- Your company operates an employee share scheme or arrangement.
What is reportable to Revenue and the relevant forms to be completed?
| Forms | Share scheme | Reportable to Revenue |
| ESA | Restricted share units (RSUs) – Share and cash settled Discounted/free/matching shares Employee share purchase plans (ESPP) Restricted shares Convertible securities Forfeitable shares Phantom shares Stock appreciation rights Growth/hurdle/flowering shares Other shares | If shares were granted, vested or disposed of or you made a cash payment equivalent of shares. |
| RSS1 | Share options and any other rights to acquire shares or assets awarded to employees and Directors | If any unapproved options were granted, exercised, transferred or released |
| KEEP1 | Details of qualifying share options granted | If any KEEP options were granted, exercised, transferred or released |
| ESS1 | Approved profit sharing (APSS) schemes | Return due for every year of assessment |
| SRS01 | Save as you earn (SAYE) schemes | Return due for every year of assessment |
| ESOT1 | Approved employee share ownership trust (ESOT) schemes | Return due for every year of assessment |
Common issues with share reporting
Employers often do not recognise that share transactions are reportable via share reporting return or may mistakenly fail to deduct income tax, USC and PRSI through the PAYE system.
This oversight might only become apparent when the annual share reporting return is being filed.
Common issues with share reporting include:
The international aspects of share schemes are complex where employee either arrive in Ireland or depart from Ireland during the vesting period of share schemes. The employer must determine the obligation to apply Irish payroll to the gain arising. This is particularly relevant in the case of Restricted Stock Units (RSUs) where some concession can apply for a non-domiciled person who has both Irish and foreign workdays in the year. Specific advice should be taken in such circumstances.
As of 1 January 2024, employees will no longer be chargeable persons as a result of exercising a share option. The obligation will be put on the employer to remit Income Tax, PRSI and USC through payroll.
Penalties for not complying with share reporting deadlines
Revenue does not issue reminders to file the share reporting returns. Failure to comply to these annual return deadlines may result in penalties. Companies can also lose their eligibility to operate Revenue approved schemes such as SAYE and KEEP schemes.
Next steps for your share reporting returns
We recommend undertaking regular reviews of your Irish employee share schemes as part of the annual reporting cycle.
This helps ensure that your arrangements remain compliant with current Irish tax legislation and any updates to Revenue guidance or practice, while also confirming that the schemes continue to meet their intended commercial and reward objectives.
Conducting a review of your share scheme reporting requirements for 2025 to ensure you have sufficient time to gather the necessary information and timely submission ahead of the 31 March 2026 deadline. If you have any questions or concerns about the share or need assistance with keeping up to date with your filing obligations, please contact the RSM Tax Team.
