Company directors who drew no dividends in 2025-26 face a heightened risk of an HMRC penalty, as they must still insert “zero” on a new part of their tax return, warns Integro Accounting.
In fact, new dividend disclosure requirements for 2026 — enforceable with £60 fines — apply to directors who “haven’t even taken any income from their business”, the accountancy firm says.
Adding to where dividends show up on a tax return, the requirements affect the SA102 Employment pages, and mean such directors must “enter a zero” or face the penalty, cautions Integro’s boss.
“Those most likely to breach the 2025 Income Tax (Additional Information to be included in Returns) Regulations aren’t the directors receiving dividends, but those who aren’t,” Christian Hickmott warns.
At a glance:
- Directors of close companies who took no dividends in 2025-26 must enter “zero” in SA102’s box 7.3 (dividends received) or risk a £60 HMRC penalty.
- It’s one of the new fields on a personal tax return for directors to fill in under “Secondary Employment,” and there are four new boxes in total: 7.1 (company name), 7.2 (company registration number), 7.3 (dividends received), and 7.4 (percentage shareholding — enter “zero” if nil).
- Integro Accounting says directors who receive dividends are arguably less at risk of the £60 penalty for not completing the fields, because their software usually flags up the four new fields and/or their accountant should’ve already drawn their attention to the quartet.
- Beansprout Consultancy founder Helen Christopher told Integro that HMRC owes taxpayers a ‘sensible period of education and adjustment’ before penalties should become its focus.
- Integro and Beansprout are both calling on HMRC for a 12-month penalty moratorium on this new, four-fold information disclosure requirement for close company directors.
- Mellor & Co founder Anthony Mellor told Integro that £60 is a fair penalty, but not when tied to rules pending clarification — and he fears the new boxes are HMRC’s opening move into scrutinising directors’ salary-dividend splits, potentially with a view to launching enquiries.
Who do the new SA102 information disclosure rules apply to?
The new disclosure requirements cover all close company directors, but those in receipt of dividends may be less at risk of a penalty, hints Integro’s Mr Hickmott, a 16-year contractor tax specialist.
“If a director is receiving dividend income, there’s a good chance it’s already recorded via their accounting software,” he explains.
“Often, the software will flag up that additional dividend information now required by HMRC under the 2025 regulations, provided that the software also supports personal tax return reporting.
“Similarly, where a director has an accountant, this new extra disclosure — which affects tax returns that must reach HMRC by January 31st 2027 — is likely to already be on the accountant’s radar.
“Therefore, the big penalty risk sits with dormant company directors, or those who haven’t even taken any income from their business during the year. Many of these will naturally assume there’s nothing to report and simply leave the section blank, not realising HMRC expects them to enter a zero.”
How can directors meet new tax return information disclosure requirements?
To help meet the new disclosure requirements, directors must input their company’s name, registration number and “dividends you received”, with a nil amount received requiring the zero.
These three new requirements are on the SA102 Employment page entitled “Secondary Employment,” and appear as boxes 7.1, 7.2 and 7.3, respectively.
What is a close company for tax purposes?
A fourth new requirement applies: directors of these “close companies” (defined by HMRC as any company with “five or fewer participators”) must also fill in 7.4 — “percentage shareholding”— and again, should input “zero” to denote a nil percentage.
In summary, for company directors (with five or fewer participators — which will be most of the UK’s contractor companies), the four new boxes are:
- Box 7.1 — Company name
- Box 7.2 — Company registration number
- Box 7.3 — Dividends received (enter “zero” if none)
- Box 7.4 — Percentage shareholding (enter “zero” if nil)
Where do I find the employment pages on my tax return?
The page containing the four new data fields (boxes 7.1-7.4) is numbered “Page E2” on HMRC’s example tax return, and a tax return’s employment pages are known as supplementary pages.
In their own tax return, directors can find the relevant employment page by searching for the HMRC prompt at the top of the page: “Complete an employment page for each employment or directorship.”
Is HMRC’s guidance on the new disclosure rules good enough?
ATT, a tax body, has described HMRC’s guidance on the new, four-fold disclosure requirement as “limited,” making practical tips from trusted accountants indispensable.
The ATT’s unflattering description of the official guidance on filling in the new data fields comes despite the requirements representing a significant change.
In fact, until now, when self-assessing (i.e. pre-2025-26 income), directors only had to tick box 6 of the SA102 to say that they were a director and tick box 7 if it was a “close company.”
Will HMRC waive penalties for directors who make honest mistakes?
Chartered accountant Helen Christopher, of Beansprout Consultancy, believes that “whenever a new reporting requirement is introduced, there should be a “sensible period of education” by HMRC.
She says there also needs to be a similarly sensible period for taxpayer “adjustment” — and only once both education and adjustment are done, should penalties be a focus for HMRC.
“However, these [SA102] changes don’t appear to have been widely publicised, meaning many directors may simply be unaware of what is now expected of them,” Ms Christopher told Integro Accounting.
“Compare that with Making Tax Digital, which has been supported by a significant awareness and education campaign, and even then, HMRC recognised the need for a softer landing on penalties.
“The same principle should apply here. For the first year, the priority should be helping company directors understand and comply with the new requirements, rather than penalising genuine mistakes.”
Has HMRC promised a ‘considered approach’ to SA102 penalties?
HMRC has reportedly vowed to take a “considered approach to directors who’ve made reasonable efforts to meet their obligations,” when it was asked in August 2026 about non-completion of boxes 7.1-7.4.
But in line with the call for a 12-month moratorium on HMRC penalties — by Beansprout Consultancy, a financial growth advisory — Integro isn’t sure the Revenue’s vow goes far enough.
In fact, like Beansprout, Integro believes HMRC penalties should be on the shelf for year one, just while director awareness and understanding of their new SA102 duties beds in.
Does HMRC’s own guidance contradict the legislation?
Integro Accounting’s managing director Christian Hickmott says: “If HMRC’s aim is better data collection, a sensible approach would be to prioritise education and clear communication during the first year, rather than relying on penalties to drive awareness.
“It seems harsh to penalise otherwise compliant directors who’ve made honest errors, especially given the mixed messages in HMRC guidance.”
To evidence those mixed messages, Hickmott cited HMRC’s SA102 Employment notes and SA150 Tax Return notes, which both indicate the Employment pages are only needed where directorship income is received. Yet he observes that the legislation itself requires all directors to disclose — regardless of whether they receive directorship income.
“It’s a key distinction,” Integro’s MD says. “The compliance issue here isn’t necessarily about undeclared income or tax avoidance; it’s about whether directors are aware of a new administrative requirement.”
Is HMRC updating its guidance for directors who self-assess?
Beansprout Consultancy’s Helen Christopher, who founded the financial growth advisory in 2023, said she welcomed reports that HMRC claims it will be updating its tax return guidance for directors.
But even new guidance won’t head off an HMRC approach that she sounds increasingly concerned about — on behalf of directors now facing £60 penalties for simply failing to insert a “0” on a form.
A former group chief operating officer, who originally qualified as an accountant with PwC, Ms Christopher told Integro: “If further changes to the penalty regime follow, they need to be proportionate, fair and focused on encouraging compliance, rather than catching people out.”
Is the £60 penalty itself fair?
Another chartered accountant, Anthony Mellor, signalled that it’s not the penalty figure of £60 he objects to — which probably meets any ‘proportionate, fair and focused’ test — but HMRC tying it to rules that are still pending clarification.
“It seems to me that, as a sanction, £60 is modest. Yet penalising an innocent mistake under rules which are themselves still being clarified is not,” the boss of Mellor & Co, an ICAEW member firm, said in a statement to Integro.
Is HMRC being disproportionate with this new director/dividend disclosure requirement?
However, spreadsheet and Excel specialist Mr Mellor fears there may be even more disproportionality at play: “Be aware, HMRC is not merely asking taxpayers to disclose [total] taxable dividends as usual, as an amount that’s already reported,” he says.
“Rather, it is imposing an additional information regime, partly involving corporate particulars that government already possesses. As I’ve seen frequently in my nearly four decades operating as a qualified accountant, HMRC is trying to cut corners at the taxpayer’s expense — whereby we join up the dots for them, at odds with its claims that it has excellent software to do all this already. It smacks, to me, of organisational laziness.”
Could the new disclosure rules lead to wider HMRC investigations?
An accountant for 37 years, Mellor worries there’s probably mission creep on the taxman’s part, too.
“I would not say that HMRC already knows the amount of dividends received by each shareholder: Companies House records do not establish that in the same way. Therefore, what this looks like to me is a jumping-off point for HMRC to launch PAYE enquiries, including where it decides your dividends are ‘excessive’ and your salary ‘too low.’
“In short, I fear it [new information requirements on director tax returns at SA102] is a legalised fishing expedition, which makes tailored advice from your accountant, in conjunction with reading the take of the Association of Taxation Technicians (ATT), an absolute must.”
How can company directors with no dividends avoid HMRC’s sin bin?
“There’s no doubt that additional information requirements on the personal tax returns of close company directors are ruffling a few feathers,” reflected Mr Hickmott, speaking from Integro’s London office at Blackwell House.
“But, pending that further promised guidance from HMRC, at this stage, my sense is that the people most likely to get caught out are not the directors receiving dividends, but those who aren’t — even though entering zero, rather than leaving box 7.3 blank, is enough to keep this small contingent of directors out of HMRC’s sin bin.”
If you’re unsure how to answer boxes 7.1–7.4 on the SA102 Employment pages, Integro’s self-assessment teams in London, Cheltenham, Leighton Buzzard and Gloucester can check your tax return and have it back to you well before the January 31st 2027 deadline.
