HMRC updates disclosure guidance for directors

HMRC has updated its guidance on the new disclosure requirements for company directors that apply from the 2025-26 self assessment tax year.

HMRC has confirmed that it has updated the guidance in the ‘How to fill in your tax return’ notes to provide further clarity for company directors completing the employment supplementary pages in their self assessment return.

New disclosure requirements for close company directors under The Income Tax (Additional Information to be included in Returns) Regulations 2025 apply for self assessment returns for the 2025-26 tax year onwards.

HMRC has confirmed the following updates have been made:

• Making clearer that individuals who are already required to submit SA returns and were directors of UK companies during the tax year, including dormant companies, must provide additional information through the SA102 Employment pages.
• Confirming that relevant directors required to submit SA returns must generally report each directorship through an SA 102 ‘Employment’ page, including where no remuneration or shareholding exists for that tax year.
• Explaining the reporting requirements for certain directors of non-UK companies, charities and community interest companies, taking into account whether payments or benefits have been received in respect of the directorship. (HMRC has exercised its Care and Management powers under Section 1 of the Taxes Management Act 1970 not to enforce the new reporting requirements for specific scenarios and has made clear in its guidance that those directors do not need to provide the additional information).
• Providing guidance for customers using the online reporting system on how to report directorship details where the number of employments and directorships exceeds the number of available Employment pages. Remaining directorship details should be provided in the "Any other information" section of the return.

HMRC has also confirmed that it will take a considered approach to compliance on a case-by-case basis, taking account of the relevant facts and circumstances, including the reasonable efforts customers have made to meet their obligations in light of the information and guidance available to them at the time.

We’ve recently discussed these new disclosure requirements in previous articles:

• Director’s loan accounts: HMRC scrutiny, new disclosures and what close companies should know.
• New reporting requirements for close company dividends – what’s changing from 2025/26.

These updates are included in HMRC’s September 2026 Agent Update which also covers a number of other matters.

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