HMRC process
HMRC EMI valuation: VAL231, the timetable and the 2026 limits
Updated
An HMRC EMI valuation is a share value you ask HMRC's Shares and Assets Valuation team to agree on form VAL231 before you grant options; HMRC aims to agree one within 4 weeks of having everything it needs. From 6 April 2026 the company option limit is £6 million.
Ask about an EMI valuation A minute of questions about the company and the options. We read it ourselves and reply directly. Free, no obligation.
How you ask
The request is form VAL231, a share valuation check for Enterprise Management Incentives, sent to HMRC's Shares and Assets Valuation team with the company's accounts and the proposed value.
Source: GOV.UK, VAL231 share valuation check for EMI
HMRC aims to reach an agreed valuation within 4 weeks of getting all the information it needs.
Source: GOV.UK, Shares and assets valuations for tax
The limits that decide whether EMI is open to you
- Per employee: options over shares worth up to £250,000 in a 3-year period.
- Company option limit: £6 million for options granted from 6 April 2026, up from £3 million.
- Gross assets: £120 million or less from 6 April 2026, up from £30 million.
- Employees: fewer than 500 full-time, up from 250.
- Exercise period: up to 15 years, up from 10.
The per-employee limit and the gross assets test are on HMRC's EMI page.
Source: GOV.UK, Enterprise Management Incentives
The 2026 changes, and the rule that options granted on or before 5 April 2026 keep the old limits, are in HMRC's bulletin 64.
Source: HMRC, Employment related securities bulletin 64
The policy paper sets out the same increases for contracts granted on or after 6 April 2026.
Source: HMRC policy paper, expanding the EMI limits
What it costs to have the valuation prepared
The cost is the adviser who prepares the valuation and the request. Published UK fees run from £1,895 to about £2,000 one-off, or £2,699 a year on a subscription, read on 15 to 27 October 2026.
Source: UK EMI Valuation Fee Index: every row, with its source