You'll need to complete an annual notification by 6th July
Although the HMRC notification requirements for unapproved options are much less than that for EMI, they do exist if you're issuing unapproved options to UK employees and directors.
Unlike EMI, you don't need to complete an initial notification, but you will need to complete an annual notification by 6th July each year for the previous financial year's activity.
This is a similar process to EMI, in that you first need to notify them of the existence of the scheme, then return after about 5 working days to notify the details. So it's important to leave plenty of time before the deadline.
Unapproved options are considered "Other ERS Schemes and Arrangements."
Please follow the gov.uk guidance for this process, plus the ODS/CSV that must be used for detailed returns here.
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