HMRC Introduces New Close Company Self-Assessment Disclosure Requirements
What changed, who is affected, and what incorporated landlords need to document before April 2026
Time to read: 2 minutes
From 6 April 2025, HMRC introduced new close company self-assessment disclosure requirements for directors of incorporated businesses. The change applies to the 2025/26 tax return, which opens for filing in April 2026. Most landlords operating through a limited company structure fall within scope.
What Has Changed
The new obligations come under The Income Tax (Additional Information to be included in Returns) Regulations 2025. Directors of close companies must now report additional information on their self-assessment tax return. A close company is broadly a UK-resident company controlled by five or fewer shareholders. Most small and family-run property companies meet this definition.
The new disclosures require directors to report:
- The company name and registration number
- Total dividends received from that company during the tax year, reported separately from other dividend income
- The highest percentage shareholding held at any point during the year
A separate employment page (SA102) is required for each directorship. A single white-space disclosure listing multiple directorships does not satisfy the requirement.
What This Means for Landlords
Landlords who hold property through a limited company and draw dividends need to review their record-keeping. The return for 2025/26 will require more granular data than previous years. HMRC will cross-reference director disclosures against corporation tax returns filed at Companies House.
The penalty for incomplete or missing disclosures is £60 per omission. Multiple penalties can apply within a single return.
Director loan accounts also come under increased scrutiny. Informal withdrawals from a company bank account carry tax risk if the loan account remains overdrawn nine months after the company’s financial year-end.
What Landlords Should Watch Next
HMRC is consulting on wider close company reporting requirements. These would require companies themselves to disclose transactions with directors, including loans, dividends, and asset transfers. No implementation date has been confirmed.
Summary
Incorporated landlords should review their 2025/26 records now. Dividend receipts, shareholding percentages, and director loan account positions all need to be accurately documented before filing opens. Structured record-keeping makes this transition straightforward.
