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Share reporting obligations; deadline 31st March

The deadline for share reporting is 31st March 2023. If you require assistance completing the Revenue documents, please don’t hesitate to contact us and we will return your call the same day.

Filing obligations

Employer and trustees

If you are an employer operating share schemes or a trustee of certain approved share schemes, you have an obligation to file an annual return.

The standard filing deadline is 31 March following the year in which the activity arose. For example, returns in respect of 2022 activity are due by 31 March 2023. It should be noted that penalties for failure to make returns may apply.

Employees

On exercise of an unapproved share option, your employee will become a chargeable person. They must submit payment of the Relevant Tax on Share Options (RTSO) within 30 days accompanied by the relevant return RTSO1.

For more information refer to How to calculate and pay Relevant Tax on Share Options.

Share-related returns

The return to be filed is dependent on the type of share award or share option involved.

FormShare Scheme/DetailsWhen to file
Form ESARestricted Share Units (RSUs) – Share & Cash SettledDiscounted/Free/Matching SharesEmployee Share Purchase Plans (ESPP)Restricted SharesConvertible SecuritiesForfeitable SharesPhantom SharesStock Appreciation RightsGrowth/Hurdle/Flowering SharesOther sharesIf during the reporting period, you granted shares, or they were vested or disposed of; or you made a cash payment equivalent of shares
Form RSS1Share Options and any other rights to acquire shares or assets awarded to employees and DirectorsIf during the reporting period, unapproved share options were granted, exercised, transferred or released
Form KEEP1Details of qualifying share options grantedIf during the reporting period, KEEP options were granted, exercised, transferred or released
Form ESS1Details of Approved Profit Sharing (APSS) schemesYou must file a return for every year of assessment
Form SRSO1Details of Save As You Earn (SAYE) schemesYou must file a return for every year of assessment
Form ESOT1Details of approved Employee Share Ownership Trust (ESOT) schemesYou must file a return for every year of assessment

Nil returns

If you are a trustee of an approved share scheme, you are required to file an annual form (ESS1/SRS01/ESOT1) for any year of assessment. This includes the filing of nil returns where no reportable events have taken place during the year in question.

For any other share schemes, you do not need to file a nil return if no reportable events have taken place during that period.

Amended returns

You can amend a return previously uploaded in Revenue Online Service (ROS).

Refer to Chapter 15 of the Share Schemes manual for further instructions.

Tips and recommendations

When completing your return

You should pay special attention to the following:

  • report all monetary values in Euros
  • remove apostrophes from surnames
  • ensure a Person Public Service Number (PPSN) is available for all employees
  • do not leave blank rows in between blocks of data. This may prompt an error message in certain returns (Form ESA)
  • some returns may require you to enter a unit share price. Other returns may ask you to introduce the total market value of the shareholding. Ensure you enter the correct values as requested
  • if you copy and paste values from a different file into the return:
    • do not to transfer scientific or non-numeric characters into the Numeric fields of the form
    • use the correct decimal separator, decimal points rather than decimal commas
  • do not reuse a return from a previous year. Ensure you use the latest version of the spreadsheet available on the Revenue website.

Refer to the different chapters of the Share Scheme Manual as they may contain reporting examples for particular schemes.

When filing your return

  • Ensure you are registered for ‘Share Scheme Reporting’ (SSR) on Revenue Online Service (ROS). Your SSR registration will be linked to your CT registration.
  • If you are logged on using a ROS Sub Cert, you may not see the SSR option. Ensure your ROS Administrator has updated your SSR permissions.
  • ‘Bad file name’ error – Save your completed return to a local or network drive before converting it to a .zip format for uploading.
  • Ensure your file is not password protected.
  • You can only submit your return through ROS. You cannot use email or MyEnquiries.

The instructions and explanatory notes on the completion and filing of the Forms are included in the relevant return and Chapter 15 of the Share Schemes manual.

Source: Share reporting obligations (revenue.ie) March 2023.

McMahon & Co
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