Entity Setup

Maximising Share Schemes: EMI, CSOP & PISCES Opportunities Post-April 2026

Changes to Enterprise Management Incentives (EMI), CSOP and PISCES from April 2026 offer scaling companies and employees major tax benefits—if structured properly.

By NomadicTax Research Team • 5-8 min read • April 9, 2026

## Overview of Schemes **EMI (Enterprise Management Incentives)** and **CSOP (Company Share Option Plans)** are tax-advantaged schemes that allow employees to acquire shares with favorable taxation. **PISCES** (Private Intermittent Securities and Capital Exchange System) is a trading platform to facilitate liquidity events for such schemes. ([gov.uk](https://www.gov.uk/government/publications/budget-2025-document/budget-2025-html?utm_source=openai)) ## Key Changes from 6 April 2026 - **Expanded thresholds for EMI**: * Employee limit raised from 250 to **500** ([gov.uk](https://www.gov.uk/government/calls-for-evidence/tax-support-for-entrepreneurs-call-for-evidence/tax-support-for-entrepreneurs-call-for-evidence?utm_source=openai)); * Company gross assets test increased from **£30 million to £120 million** ([gov.uk](https://www.gov.uk/government/calls-for-evidence/tax-support-for-entrepreneurs-call-for-evidence/tax-support-for-entrepreneurs-call-for-evidence?utm_source=openai)); * Share option limit (value granted) doubled from **£3 million to £6 million**. ([gov.uk](https://www.gov.uk/government/calls-for-evidence/tax-support-for-entrepreneurs-call-for-evidence/tax-support-for-entrepreneurs-call-for-evidence?utm_source=openai)); * Holding period maximum increased from 10 to **15 years**, applicable also to existing contracts under certain conditions. ([gov.uk](https://www.gov.uk/guidance/employment-related-securities-bulletin-62-november-2025?utm_source=openai)). - **PISCES Inclusion for EMI/CSOP Contracts**: Contracts granted **before 6 April 2028** can be amended to include PISCES as an **exercisable event**, allowing liquidity via this platform while retaining tax benefits. ([gov.uk](https://www.gov.uk/guidance/employment-related-securities-bulletin-62-november-2025?utm_source=openai)). - **EIS and VCT Scheme Limits**: Annual company investment limits raised to **£10 million** (£20 million for Knowledge Intensive Companies), and lifetime limits to **£24 million** (£40 million for KICs). ([gov.uk](https://www.gov.uk/government/calls-for-evidence/tax-support-for-entrepreneurs-call-for-evidence/tax-support-for-entrepreneurs-call-for-evidence?utm_source=openai)). - **Reduction in VCT upfront income tax relief** from **30% to 20%**, effective 6 April 2026. ([gov.uk](https://www.gov.uk/government/calls-for-evidence/tax-support-for-entrepreneurs-call-for-evidence/tax-support-for-entrepreneurs-call-for-evidence?utm_source=openai)). ## Action-Steps for Companies & Employees ### Companies: - Review eligibility: companies that were too large under old limits may now qualify for EMI. Also audit existing share option contracts for opportunities to amend for PISCES event. - Plan option grants: schedule new grants after 6 April 2026 to utilise higher thresholds. Ensure contracts drafted with care to meet conditions. - Liaise with legal/tax advisors to properly register or amend schemes; ensure compliance with notice, reporting, and end-of-year return obligations. { ### Employees: - Understand the new limits and how they affect share value and retention incentives. - For those holding options, consider whether waiting for a PISCES event under the revised scheme will offer liquidity while preserving tax advantages. - Tax planning: gains under EMI and CSOP remain favorable—capital gains, not income tax—and may reduce exposure to higher tax rates on employment income. ## Example Case: Startup Scaling Up **Startup “InnovateAI”** currently has 300 employees, £25 million gross assets. Under old EMI rules, did not qualify (employees >250 + asset limit exceeded). After threshold changes on **6 April 2026**, InnovateAI becomes EMI-eligible. They grant **£5 million** of share options to key staff under new 15-year holding rule. They also incorporate a clause allowing PISCES exit event, so early-stage investors can realise gains without full exit or IPO. ## Risks & Caveats - Amended contracts may require shareholder agreement and reworking documentation—legal cost. - PISCES platform liquidity depends on market and investor uptake—not guaranteed. - Reduced upfront relief for VCTs means investment return expectations must be recalibrated. **Conclusion**: The April 2026 reforms to EMI, CSOP, and associated investment schemes represent a major opportunity for scaling UK businesses and employees. Proper structuring now can deliver tax-efficient rewards and better liquidity while navigating the changing relief landscape.