UK Growth Plan (‘Mini-Budget’) 2022 – Changes to the Company Share Option Plan (CSOP) Regime


On 23 September 2022, the UK Government announced some significant changes to the Company Share Option Plan (CSOP) regime in its Growth Plan (widely referred to in the media as a ‘Mini-Budget’).

From April 2023, qualifying companies will be able to issue up to £60,000 of CSOP options to employees, double the current £30,000 limit. The ‘worth having’ restriction on share classes within CSOP will also be eased, better aligning the scheme rules with the rules in the Enterprise Management Incentive (EMI) scheme and widening access to CSOP for growth companies.

Here are three key insights, of particular relevance to our practice:

  1. This is beneficial for fintech companies and later stage private companies that do not qualify under the EMI scheme or have outgrown the EMI limits.
  2. Publicly listed companies and fintech companies already granting options under a CSOP can take advantage of the increased £60,000 limit, allowing these companies to offer larger awards to employees.
  3. The changes to the CSOP regime indicate the UK Government’s general support of employee share schemes, particularly in the life sciences and technology sectors.

The draft legislation will be introduced in a future Finance Bill supporting these changes, which the Orrick Incentives team will review and provide further insight on once published.

If you have any questions or would like to discuss, please contact Anna Humphrey.