If you run a limited company, your 2025/26 Self Assessment return asks for more than it used to. HMRC has now confirmed that two small groups of directors can skip the new questions. Everyone else must answer them, even if the company paid them nothing. This guide explains what changed, who qualifies for the exceptions and what to do before you file.

What has changed for company directors?

Directors who already file a tax return must now complete extra boxes on the SA102 Employment pages. The rules come from the Income Tax (Additional Information to be included in Returns) Regulations 2025. Boxes 6 and 7 used to ask whether you were a director and whether the company was close. Answering was optional. From 2025/26, it is compulsory.

If you direct a close company, you must also complete boxes 7.1 to 7.4. These ask for the company’s name and registered number, the dividends you received from it and your percentage shareholding. A close company is broadly a UK company that five or fewer participators control. It also includes a company that any number of participators who are directors control. If your shareholding changed during the year, report the highest percentage you held.

HMRC wants to see which dividends came from your own company and which came from elsewhere. That is why the questions now matter.

Exception one: unpaid directors of charities and CICs

On 8 September 2026, HMRC updated the SA150 notes to clarify that directors of a registered charity or community interest company (CIC) need not complete the close company boxes. The SA150 notes set out the condition. You must have “did not receive, and did not become entitled to receive” any payment of the kind listed. That covers employment income, dividend income and any other distribution. The test applies to the charity or CIC itself and to any connected company.

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This exception applies to a narrow group. It covers directors of registered charities and CICs who took nothing from the company. Charity trustees who sit on the board of a charitable company will often fit. If you receive a salary, a dividend or any other distribution, the exception falls away. You then complete the boxes as normal.

Trustees should still take care. A company limited by guarantee can still be a close company, and many trustees do not think of themselves as directors of one. Check your position before you assume you are exempt.

Exception two: directors of non-UK companies without pay or benefits

The second group is directors of non-UK companies. The SA150 notes tell taxpayers to complete an Employment page for a non-UK company only if they received pay or benefits. HMRC has explained the reporting requirements for certain directors of non-UK companies, taking account of whether they received payments or benefits. A non-UK director who received nothing from the role does not need to provide the additional information.

Check the wording in the notes against your own facts. A director who received pay or benefits from a non-UK company remains within the rules.

Why HMRC is not enforcing these cases

HMRC has not changed the law for these groups. It has used its care and management powers under section 1 of the Taxes Management Act 1970 not to enforce the new requirements in these specific scenarios. The regulations still apply. HMRC has simply chosen not to chase these directors.

This matters because the exceptions depend on HMRC’s published guidance. Keep a note of your reasoning in case HMRC ever asks.

Who has no exception?

Many directors assume the new rules cannot apply to them. Most of those assumptions are wrong. HMRC has confirmed the following points.

Unpaid directors must complete the boxes. Directors who receive no remuneration or dividends still have to complete the close company boxes. Directors of dormant close companies must also complete them. If you hold no shares, enter 0% in box 7.4. If you received no dividends, enter 0 in box 7.3. Do not leave either box blank.

A company that was close for only part of the year still counts. The same applies if the director never owned any shares.

The rules only apply to directors who already file a Self Assessment return. Directors outside Self Assessment do not need to register just to report close company information.

You also need a separate SA102 page for each directorship. If you file online and run out of Employment pages, put the remaining directorship details in the “Any other information” section.

What happens if you get it wrong?

HMRC may charge a £60 penalty if you do not complete the close company boxes correctly. The penalty does not depend on how many directorships or boxes you missed. HMRC has also said it will take “a considered approach to compliance on a case-by-case basis”. It will consider the reasonable efforts taxpayers have made. That is a helpful signal, but it is no reason to guess.

What should you do before you file?

The paper return deadline is 31 October 2026. If you file online, you have until 31 January 2027. Start by listing every company you directed during 2025/26. Include dormant companies, unpaid roles and any directorships you held for only part of the year.

Next, check whether each company is a close company. Then gather the registered numbers, your dividend totals and your highest shareholding percentage for the year. If you direct a charity or CIC, confirm whether you or any connected company received anything from it.

How CMA Accountancy can help

Getting these boxes right takes care, especially when you hold several directorships. The exceptions are narrow, and a wrong assumption can cost you a penalty. At CMA Accountancy, we can review your directorships, confirm whether an exception applies and prepare your self-assessment return accurately. Contact the team today to make sure your 2025/26 return is complete and on time.