HMRC rewrote the director's tax return and most clients have not noticed
The 2025/26 self assessment season is the first one in which being a company director is no longer a tick box. It is a data return.
Until now, a director of a close company confirmed the fact in a single box on the SA102 employment pages and moved on. From the 2025/26 return onwards, that box has company behind it. For each close company where the taxpayer is both a director and a shareholder, the return now asks for the company name, the company registration number, the dividend income received from that company during the year, and the highest percentage of share capital held at any point in the year.
The percentage is the part most people get wrong. It is not the holding at 5 April. If a share transfer moved someone from 60% to 25% in October, the figure HMRC wants is 60%. And each directorship needs its own SA102 page, repeated in full, even where the director took nothing at all from that company.
These answers became mandatory when the 2025/26 returns opened for filing on 6 April 2026. The online deadline is 31 January 2027. A penalty of 60 pounds may apply where the required information is not provided.
HMRC is still clarifying the edges as firms hit them. On 8 September 2026 it updated the self assessment return notes to confirm that directors of a registered charity or a community interest company do not need to complete the close company boxes where they did not receive, and did not become entitled to receive, any employment income or dividend income from it. The ICAEW had been pressing for that answer since May, which tells you how much of this is still being worked out in public.
Why a small box change is a large amount of work
Consider what the new boxes actually require a practice to hold on file for every owner-managed client.
A dividend figure that reconciles company side to personal side. Not an approximation, not a round number written on a board minute after the fact, but a figure that will sit on a personal return next to a company registration number that HMRC can match.
A shareholding history rather than a shareholding snapshot. Firms that treat the share register as a formality only touched at incorporation will discover mid-season that nobody recorded when a spouse was added, or when a founder's holding diluted.
A full set of pages for every directorship, including the dormant company somebody forgot they were a director of, and including directorships where no money moved.
Most practices have that information somewhere. Very few have it in a form that can be pulled for 400 clients in January. That gap is the entire story of this tax year, and it is the reason the work is worth pricing rather than absorbing.
The opportunity: HMRC just gave you a reason to call every company client
Compliance changes that create a genuine client question are the cheapest marketing an accounting firm will ever get, because the client initiates the conversation. This one creates several.
Clients with more than one directorship want to know why their return got longer. Clients with a spouse on the share register want to know what HMRC intends to do with a dataset that now links dividend income to a precise shareholding percentage. Clients who have been taking dividends on a rough monthly rhythm want to know whether their paperwork will survive the matching.
Every one of those is an advisory conversation with a fee attached, and every one of them starts with the firm being visible at the moment the question forms. That is the same pattern we set out in our guide to digital marketing for accounting firms: the firms that win on regulatory change are not the ones with the best technical answer, they are the ones whose answer is findable in the week the change lands.
There is a second reason to call now. This is not the only thing HMRC moved this autumn. The department has also started automatically signing up sole traders and landlords who should already be inside Making Tax Digital for Income Tax and have not joined, with a reported 294,000 people in scope, and the final phase of multi factor authentication for online services begins on 28 September 2026. We covered the first of those when it went live in our piece on MTD for Income Tax and the second in our note on HMRC agent MFA. A director-client hearing about all three at once from one firm forms a very different impression than one who hears about them from three different LinkedIn posts by three different practices.
What HMRC is actually building here
It is worth being clear about why a tax authority asks for a shareholding percentage it could, in theory, pull from Companies House.
The answer is matching. Company accounts and CT600s sit on one side of HMRC's systems. Personal returns sit on the other. Historically, joining the two for an owner-managed business meant a caseworker deciding to look. From 2025/26, the personal return itself carries the company registration number, the dividend taken from that specific company, and the holding that dividend was paid on. That is a structured dataset covering several million director-shareholders, arriving once a year, ready to be queried at scale.
The obvious query is the one where the dividend reported personally does not reconcile to what the company distributed, or where the split across shareholders does not match the holdings declared. The second obvious query is dividends paid where the company's reserves do not support them. Neither of those is a new risk in law. Both become very much easier to spot.
Firms that have watched HMRC's recent pattern will recognise the sequence. The department gathers structured data, runs it, and then issues nudge letters at volume rather than opening enquiries. It did exactly that with crypto holders, as we covered in our piece on HMRC crypto nudge letters, and the tax gap figures that drive the strategy are in our note on the 2026 UK tax gap.
For a practice, that means this year's filing work is next year's advisory work. The director whose share register is tidy in January is the one who does not receive a letter in the autumn, and the firm that made that point out loud is the firm that gets credited for it.
The opportunity cost: the firm that says nothing is the firm that gets compared on price
Here is what happens in a practice that handles this quietly and well, and says nothing publicly.
January arrives. The team absorbs the extra pages, chases the share registers, files on time, and bills roughly what it billed last year. The client experiences a slightly longer email chain and no visible change. When a cheaper quote arrives in March, there is nothing in the client's memory to weigh against the price, because the firm never named the work it did.
Meanwhile a competitor two towns over publishes one clear page titled around what close company directors now have to report, ranks for it inside a month because almost nobody has written it properly, and takes the enquiries from every director in the county whose own accountant has been silent. The switching behaviour is real and we have measured the pattern before in the UK client switching window.
The cost is not the lost article. It is the lost position. Search results for a new compliance term settle within weeks and then harden, because early pages accumulate the links and the engagement that keep them there. A page published in October outranks a better page published in January.
What to publish, and where it needs to sit
Three assets cover this properly, and none of them takes a week to produce.
One explainer page, not a blog post buried in a feed. Title it the way a director would search it, cover the four data points the return now wants, the highest-percentage rule, the per-directorship repetition, the 60 pound penalty and the 31 January 2027 deadline. Give it a permanent URL and keep it updated as HMRC clarifies more edges. Structured, fast-loading pages of this type are the backbone of our SEO work for practices, and they are what AI search engines quote when a director asks the same question in a chat window rather than a search box.
A practice site that converts the visit. Traffic on a compliance term is high intent and low patience. If the page loads slowly, hides the contact route, or looks like it was last touched in 2019, the visit is wasted. Our web design work for accounting firms is built around that single moment, and the incremental gains come from conversion rate optimisation on the pages that already get traffic.
One email to the existing list. Every company client on your book is affected. A short, specific email that names the four data points and asks them to confirm their share register is the least expensive revenue in the practice, and it doubles as the reason a dormant client re-engages. This is the same argument we make for email marketing generally: the list you already own outperforms the audience you have to rent.
Firms that want the underlying playbook rather than the single tactic should start with our digital marketing guide for UK accounting firms, and firms weighing this against their wider positioning can see the full picture on our UK digital marketing agency page.
The window is roughly sixteen weeks
The 2025/26 returns are already open. The deadline is 31 January 2027. Between now and then, every close company director in the UK will either hear about this from their accountant or find out about it from a search result.
Triomatic Marketing builds the pages, the practice sites and the campaigns that put UK accounting firms in the second category. You can message Aria, our AI assistant, on WhatsApp from triomaticmarketing.com, or take a free 15-minute discovery call and we will map the three assets above against what your practice already ranks for.
FAQs
What do close company directors have to report on the 2025/26 tax return?
For each close company where the taxpayer is a director and a shareholder, the SA102 employment pages now ask for the company name, the company registration number, the dividend income received from that company in the year, and the highest percentage of share capital held at any point during the year.
Is the shareholding percentage the figure at the end of the tax year?
No. HMRC asks for the highest percentage of share capital held at any point during the tax year, not the holding at 5 April. If a director held 60% until October and 25% after a share transfer, the figure reported is 60%.
What happens if a director has more than one directorship?
Each directorship needs its own SA102 page with the full set of boxes repeated, including directorships where the director received no income from that company at all.
What is the penalty for not completing the new director boxes?
A penalty of 60 pounds may apply where the required information is not provided. The online filing deadline for 2025/26 returns is 31 January 2027.
Do directors of charities have to complete the close company boxes?
HMRC updated the self assessment return notes on 8 September 2026 to confirm that directors of a registered charity or a community interest company do not need to complete the close company boxes where they did not receive, and did not become entitled to receive, any employment income or dividend income from it.
Why should an accounting firm publish about this rather than just handle it quietly?
Search positions for a new compliance term settle within weeks of the change and then harden. A firm that publishes a clear explainer in October holds the position through the January filing peak, when every affected director is searching. A firm that stays silent competes on price instead.