2025 Employer Share Scheme reporting

Filing deadline

The deadline for submitting the 2025 ESA, RSS1 and KEEP1 Returns is 31 March 2026.

Registration requirement

Employers must register with Revenue for share scheme reporting via the Revenue Online Service (ROS) before submitting the relevant forms, if not completed already. As the registration process can take a few working days or longer, we recommend completing it as early as possible to avoid any delays in meeting the deadline.

ESA Return

The ESA Return is required for the following types of share-based awards:

• Restricted Stock Units (RSUs) – both share and cash-settled.
• Restricted shares.
• Convertible securities.
• Employee Share Purchasing Plans (ESPP) unless it falls under share option legislation.
• Discounted, free or matching shares.
• Forfeitable shares.
• Growth/Hurdle/Flowering shares.
• Phantom shares.
• Stock Appreciation Rights.
• Any other awards with cash-equivalent of shares.

The specific details of an event or transaction that must be reported on the ESA Return are extensive and vary depending on the type of share award involved. The return must be submitted electronically and contains separate tabs and instructions for each share award category. Depending on the nature of the share transaction, an employer may be required to report information relating to the award or grant, vesting, exercise, forfeiture and other relevant events.

Some other points to note:

• An employer should report payment of the cash-equivalent of shares in the Form ESA for the year when the cash payment is made, even if the employee or director is no longer with the company.
• With regard to RSUs, an employer should report whether they were share-settled or cash-settled (although reporting the grant of RSUs is currently optional).
• Some individuals may, in addition to having a liability under the PAYE system in Ireland, also have a liability to income tax in a foreign country on the RSU or a portion of the RSU. Where this arises, and a double taxation agreement is in place with the other country, the individual may be entitled to a credit in relation to any amount subject to double taxation. To facilitate the granting of such relief in ‘real-time’, one of the conditions for this is that the employer must notify Revenue it is operating real-time double taxation relief via payroll, after the end of the tax year, but no later than 31 March of that following year. An employer may satisfy this obligation by completing the relevant column of the Form ESA, which is due for submission by 31 March following the end of the tax year.

The filing deadline for the 2025 ESA Return is 31 March 2026.

RSS1 Return

The RSS1 Return is for share options and other rights to acquire shares or assets awarded to employees and director. This return contains information relating to the grant, exercise, assignment, or release of share options. It also applies to employee stock purchase plans which fall under share option legislation in Ireland.

The filing deadline for the 2025 RSS1 Return is 31 March 2026.

KEEP1 Return

The KEEP1 Return must be submitted by 31 March 2026 if any company operated a Key Employee Engagement Programme (KEEP) scheme in Ireland in 2025.

Other share scheme returns

Approved Profit-Sharing Schemes (APSS):

• Trustees of an APSS must file a Form ESS1, if shares were allocated to employees in 2025.
• Filing deadline: 31 March 2026.

Save As You Earn (SAYE) Schemes:

• Employers must file a Form SRSO1 for SAYE share options granted or exercised in 2025.
• Filing deadline: 31 March 2026.

Penalties for late filing or non-filing

• Late Filing Penalties: Revenue may impose penalties for late submission of any required returns.
• KEEP Scheme: Failure to file the KEEP1 Return on time could result in the withdrawal of the scheme’s tax benefits. 

If your company would like assistance with preparing the aforementioned returns, please contact a member of our employment tax team.