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Changes to SA102 employment pages on self-assessment
The Income Tax (Additional Information to be included in Returns) Regulations 2025 has introduced significant changes to the self-assessment reporting requirements for directors of close companies. From the 2025/26 tax year onwards, individuals completing the SA102 employment pages are required to provide additional information about their involvement with close companies, marking a notable expansion of the data collected through self-assessment tax returns.
The changes form part of HMRC’s wider strategy to improve transparency around owner-managed businesses, dividend income and share ownership structures.
Background to the changes
Historically, directors completing the SA102 employment pages were asked whether they were a company director and whether the company was a close company. New regulations now require more detailed reporting, enabling HMRC to better identify and verify dividend income and shareholdings associated with close companies. The changes apply to self-assessment returns for the 2025/26 tax year and subsequent years.
What is a close company?
A close company is broadly a UK-resident company that is controlled by:
- five or fewer participators (such as shareholders), or
- any number of participators who are also directors of the company.
In practice, most owner-managed businesses, family companies and personal service companies fall within the definition of a close company.
New information required on the SA102
From the 2025/26 tax year, directors of close companies must provide additional details for each close company in which they hold a directorship.
The new disclosure requirements include:
1. Company name
The full legal name of the close company must be entered on the SA102.
2. Company registration number
The company’s registration number, as recorded at Companies House, must also be disclosed.
3. Dividend income received
Directors must report the amount of dividend income received from the close company during the tax year. Importantly, this figure must be disclosed even if the amount is nil. The dividend amount should correspond with the dividend income reported on SA100 on the individual’s self-assessment return.
4. Percentage shareholding
The taxpayer must disclose their percentage ownership of the company’s share capital. This information must also be provided even where the percentage is zero, provided the individual is a director of the close company.
Multiple directorships
Where an individual serves as a director of more than one close company, separate disclosures will be required for each relevant company. This could result in more administrative burdens for directors and agents who operate through multiple corporate structures.
Who is affected?
The new reporting obligations affect individuals who are:
- directors of close companies; and
- required to submit a self-assessment tax return.
The changes do not create a new obligation to file a tax return. Individuals who are not otherwise required to submit a return will not need to file solely because they are directors of a close company.
You should complete an SA102 for the directorship in a close company, even if no salary or benefits or dividend was received.
What are the reasons for these changes?
HMRC has indicated that the additional disclosures are intended to improve its ability to monitor dividend income and ownership structures within owner-managed businesses.
Unlike employment income, dividend payments are not routinely reported to HMRC by third parties. By collecting company-specific dividend and shareholding information, HMRC will be better positioned to identify discrepancies between company records and personal tax returns.
Penalties for non-compliance
HMRC has indicated that a £60 penalty may apply where a taxpayer fails to provide the mandatory additional information required by SI 2025/84, including close company details on the SA102.
The £60 penalty derives from Schedule 36 to the Finance Act 2008, specifically the provisions dealing with failures to comply with information requirements. However, agents should bear in mind that if omitting the close company information also results in:
- an inaccurate tax return
- undeclared dividends
- an incorrect tax liability
… then HMRC could consider penalties under the inaccuracy penalty regime in Schedule 24 Finance Act 2007, which can be substantially higher than £60 depending on behaviour and tax lost.
However, where the tax return is otherwise correct and the issue is simply that the new mandatory information boxes were left blank, HMRC’s stated position is that the relevant penalty is the £60 fixed penalty.
Practical steps for directors and advisers
To ensure compliance with the new requirements, directors should:
- maintain accurate records of dividend declarations and payments
- retain documentation supporting share ownership percentages
- confirm company registration details before preparing returns
- review ownership structures where multiple classes of shares exist
- communicate with their agents early to ensure all required information is available before filing deadlines.