EMI vs CSOP vs SAYE vs SIP Share Scheme Comparator 2026/27
UK share schemes compared for 2026/27: EMI, CSOP, SAYE and SIP limits, when Income Tax, NI and CGT apply, and how unapproved options and RSUs differ.
Scheme comparison
| Scheme | Employee limit | Tax at grant | Tax at exercise / vesting | Tax at sale | Who can use it |
|---|---|---|---|---|---|
| EMI | £250,000 of options in a 3-year period | None | None if the price is at least market value at grant and exercise is within the 10 or 15 years the agreement allows | CGT; Business Asset Disposal Relief at 18% if the option was granted at least 2 years before the sale | Key staff at independent trading companies with gross assets of £120m or less and fewer than 500 full-time employees (options granted from 6 April 2026) |
| CSOP | £60,000 of options (£30,000 for options granted before 6 April 2023) | None | None if exercised between 3 and 10 years after grant | CGT | Selected employees, no size limit like EMI |
| SAYE | Save up to £500 a month over 3 or 5 years | None | None; interest and any bonus are tax-free | CGT, unless moved to an ISA within 90 days or to a pension directly when the scheme ends | All employees |
| SIP | £3,600 free shares a year; partnership shares up to the lower of £1,800 or 10% of income; up to 2 matching shares per partnership share | None | No Income Tax or NI if kept in the plan for 5 years | No CGT if sold straight from the plan | All employees |
| Unapproved options | None | None (typical) | Income Tax on (market value - price paid); also PAYE and NI if the shares are readily convertible assets | CGT on any further gain | Awards above the tax-advantaged limits |
| RSU | None | None | At vesting: Income Tax on the market value; PAYE and NI if readily convertible | CGT on any further gain | Typically listed companies |
EMI limits rose for options granted on or after 6 April 2026: the company option limit from £3 million to £6 million, gross assets from £30 million to £120 million, employees from 250 to 500 and the maximum exercise period from 10 to 15 years (HMRC employment related securities bulletin 62). Options granted at a discount to market value are taxed on the discount.
Frequently asked questions
Which scheme is most tax-efficient?
It depends on the company and the employee. EMI can mean no Income Tax or NI on exercise and Business Asset Disposal Relief at 18% on sale, but only smaller independent trading companies can offer it. SIP shares kept in the plan for 5 years are free of Income Tax and NI, and there is no CGT if they are sold straight from the plan, within much lower annual limits.
SAYE or SIP: which fits an all-employee scheme?
Save As You Earn (SAYE): employees save up to £500 a month for 3 or 5 years and can then buy shares at a fixed price, or simply take their savings back if the shares have fallen. SIP: free, partnership and matching shares held in a trust, with no Income Tax or NI if they stay in the plan for 5 years.
How are cross-border employees taxed on share awards?
Awards earned while working in more than one country can be taxed in each. The UK charge depends on how much of the award relates to UK duties over the period it was earned, and relief for foreign tax may be available. HMRC sets out the rules in its Employment Related Securities Manual (ERSM162000 onwards). Specialist advice is essential.