You only need to tell HMRC about unapproved options if they have been awarded to employees or directors.
An initial filing needs to be made by July 6th following the tax year in which the options were granted. Additional filings must be made each subsequent year until the scheme is closed.
The file required, along with detailed HMRC guidance notes can be found here:
For the initial notification:
Fill in the first sheet, Other_Grants_V3. All 4 columns should be filled in. This is pretty self explanatory, and is just entered in aggregate for each grant date.
For subsequent annual notifications: You will either submit a nil return, if none of the unapproved options have been cancelled or exercised, or you will need to fill in the same file.
This time, fill in the second sheet, Other_Options_V3.
Most of the questions are again self-explanatory, but a few may need a little help:
2. For a normal unapproved option, no
30. Yes, if exercised, no if cancelled
33. In the case of an exercise, what was the Actual Market Value of the shares at the time.
37. Typically £0, unless a charge was made for the grant of option or other expenses were incurred by the employee or director