Senior Hiring at US-VC Backed UK Firms

A large share of the UK’s technology, fintech and high-growth businesses are funded wholly or partly by US venture capital. That funding creates a distinct category of company: a UK operating base and UK market, combined with US investor governance expectations, US reference points on pay and equity, and the commercial ambitions US venture investors bring to every portfolio company. Senior hiring in these businesses does not work quite like hiring in a UK corporate, a listed company or a PE-backed firm, and the differences catch out founders, investors and candidates alike.

Hiring senior executives at US-VC backed UK firms means dealing with several specific tensions: the gap between US and UK talent market expectations, the governance habits of US investors who are used to a more hands-on board, equity structures that may have been designed in Delaware rather than London, and a culture that shapes what effective leadership looks like. This guide explains those dynamics and how to run senior searches well in this environment. It draws on the work our scale-up executive recruitment practice does on senior appointments at venture-backed businesses.

The US VC Governance Model and UK Executive Expectations

US venture capital firms tend to run a governance model that is more interventionist than the UK private equity or listed company board models most UK senior executives have experienced. US VCs typically hold board seats, take an active part in strategic and some operational decisions, hold strong views on hiring (particularly at senior level), and expect frequent, detailed updates on performance. The board is not a body that meets quarterly to receive polished management presentations; it is an active participant that expects the management team to use it as a sounding board and to bring difficult decisions to it early.

Senior executives joining US-VC backed UK firms from listed companies or traditional UK PE-backed businesses often experience this as unusually intrusive. The expectation that the CEO or CFO will share raw data with the board, discuss options before reaching conclusions, and draw on the investors’ operating experience to solve specific problems is a different habit from the UK norm of presenting finished board papers to an oversight body. Executives who do well in this environment usually embrace it; those who resist it create friction that damages the management team’s relationship with its investors, sometimes before they have had a chance to deliver results.

It is worth separating two things that UK candidates sometimes conflate. The first is the formal legal position: a UK company’s directors owe their duties under the Companies Act 2006 to the company, whoever appointed them, and investor directors are bound by the same duties as everyone else around the table. The second is the working culture: how often the board meets, how much information it wants, and how involved individual investors expect to be between meetings. The legal framework is the same as any UK private company. The culture is where the difference lies, and it is the culture that a senior hire needs to understand before accepting an offer.

For the search process, this means assessing candidates on their board-facing behaviour as well as their functional ability. Questions worth asking in interview include how the candidate has handled an investor director who disagreed with a management recommendation, how they have reported bad news to a board, and how they decide what to bring to the board before it is resolved. References from former chairs or investor directors are often more revealing on this point than references from peers.

Compensation Structure in US-VC Backed UK Firms

US VC-backed businesses typically structure senior packages differently from UK corporate or PE benchmarks. The base salary may sit below what an equivalent UK corporate role would pay, with a larger proportion of the potential reward delivered through equity — usually share options, vesting over several years, often with an initial cliff before any options vest. The four-year vest with a one-year cliff is common in US-style plans, but it is a convention rather than a rule, and the actual terms should always be read from the plan documents.

What the equity is worth depends on the outcome the investors are backing, and that outcome is uncertain. The comparison between the options on offer and the cash the candidate is giving up needs to be made honestly in the offer process. Good practice is to show the candidate the fully diluted percentage the grant represents, the current preference stack ahead of ordinary shareholders, the strike price, and a range of exit scenarios including a downside one. Candidates who have only seen a headline number of options, without the share count or the preferences, cannot value the offer properly — and experienced candidates will ask. Our guide to constructing senior executive offers covers how to put these packages together and present them.

US investors generally expect the senior leadership team to be meaningfully incentivised through equity and accept the dilution that comes with a well-sized option pool. UK executives who have worked in PE-backed businesses, where management equity tends to be structured as sweet equity or a management incentive plan concentrated in a small team, will find the venture approach different: broader participation, options rather than shares, and value that depends on the next funding round as much as the final exit.

There is also a structural question that often surfaces late in the process: which company the options are over. Many US-VC backed UK businesses have been “flipped” so that a US holding company, often incorporated in Delaware, sits above the UK operating company. In that case, UK employees are granted options over US parent shares, under a plan written for US tax rules, with UK tax treatment layered on top. This affects whether EMI is available, how the options are taxed, and how they are valued. Those points are covered in detail later in this guide, and they should be understood by the hiring company before an offer letter goes out, not discovered during the candidate’s own tax advice.

Roles Most Commonly Hired at US-VC Backed UK Firms

VP and C-level commercial roles. US-backed UK firms at Series B and beyond are typically hiring VP Sales, VP Marketing, Chief Revenue Officer and VP Customer Success roles as their main growth appointments. US VCs have firm views on what good commercial leadership looks like at each stage, often shaped by their US portfolio, and the brief frequently asks for candidates who have already scaled a comparable business through the next phase of growth. The combination of hypergrowth commercial experience and UK and European market knowledge is scarce, and it is priced accordingly.

CFO. The CFO appointment at a US-VC backed UK firm post-Series B is one of the most consequential senior hires the business makes. The CFO manages investor reporting and the board relationship, builds finance infrastructure for scale (moving from start-up bookkeeping to institutional-grade finance), handles UK tax and regulatory obligations alongside any US filing requirements of the parent, and prepares the business for a possible IPO or trade sale. The strongest candidates have worked in venture-backed growth finance, understand SaaS or equivalent metrics such as ARR, net revenue retention, customer acquisition cost and lifetime value, and have operated with US investors on the board. Our CFO recruitment service covers these appointments, and for earlier-stage businesses a part-time or interim finance lead may be the right first step.

CPO and engineering leadership. US-backed UK technology businesses often have strong product leadership at the parent or founder level and are building UK product and engineering teams that must work within a US-led product organisation. UK VP Engineering and CTO appointments in these businesses need technical depth plus the management capability to operate across time zones and reporting lines that run to the US.

UK MD and Country Manager. For US businesses expanding into the UK, the UK Managing Director or Country Manager is the most important local hire — the person who establishes the UK operation, builds the UK team and owns the UK P&L. These are typically hired through our managing director recruitment practice, with the brief shaped around how much autonomy the UK entity will have from the US head office.

Board and investor-side appointments. As the business matures, US investors often push for an independent chair or non-executive directors with UK governance experience — particularly where the company is regulated, approaching a UK listing, or needs credibility with UK customers and lenders. These appointments sit alongside the executive hires and are covered by our VC-backed NED recruitment work.

Finding the Right Candidates

The candidate pool for senior roles at US-VC backed UK firms is concentrated in the UK technology and fintech scale-up community: executives who have built careers in high-growth businesses and who understand venture-backed growth, data-led management and equity-heavy pay. Candidates from traditional UK corporate or PE-backed backgrounds need careful assessment of how they will adapt to the pace and governance culture of a venture-backed business. Such moves are perfectly possible, but the mismatch between corporate governance habits and venture governance reality is a common early failure.

US executives working cross-border or willing to relocate are also part of the pool, particularly for roles with a transatlantic remit. They bring experience of scaling through the stages US VCs know best, relationships with US investors and customers, and familiarity with the US governance model. They will usually need UK market knowledge built around them, and may require visa sponsorship, relocation support and tax advice on moving between the two systems. Our venture capital recruitment practice also gives us visibility of executives who have worked on the investor side and want to move into an operating role.

A practical point on assessment: venture-backed candidates often present their achievements in growth metrics — ARR multiples, headcount growth, rounds raised. These numbers need context. What was the starting point, what did the market do over the same period, what was the candidate personally accountable for, and what happened after they left? Structured referencing that tests the candidate’s own contribution, rather than the company’s trajectory, is the most reliable way to separate executives who drove growth from those who were present for it.

The Founder-CEO Dynamic

Most US-VC backed UK firms are founder-led at Series A and B, and the founder’s role in senior hiring decisions is usually larger than in a PE-backed business where the investor holds more direct authority. The founder CEO may be hiring their first professional CFO, first VP Sales or first CPO — roles that take over functions the founder has owned personally and that require genuine delegation for the first time. Helping the founder articulate what the senior hire will own, where decision rights sit, and how the management team will work together is as important as the candidate search itself.

This is often where US investors and founders want different things. The investors may want an experienced operator who will impose process; the founder may want a trusted lieutenant who will carry out their vision. A search that does not resolve that difference at briefing stage will produce a shortlist that one party or the other rejects. We find it useful to brief separately with the founder and with the lead investor director, then bring the two views together into a single written brief that both sign off before the search starts.

Candidates should also be told plainly how the founder works. A strong senior executive can work well with a founder who is closely involved in the detail, provided they know that before they join. The problems arise when the role is sold as having autonomy that the founder has no intention of giving up.

How Exec Capital Approaches US-VC Backed Appointments

Exec Capital runs senior executive searches for US-VC backed UK businesses from Series A to pre-IPO. Our scale-up practice combines relationships across the UK technology and fintech leadership community with an understanding of US venture governance and of the equity structures that shape offers at these businesses. We work with US investors strengthening the leadership of their UK portfolio companies and with UK founders backed by US capital who are making their first professional senior hires.

Each search starts with a brief that reflects the growth stage the business is entering, the board’s expectations of the role, and the equity position the company can genuinely offer. We test the offer structure against the market early, so that the company knows before the shortlist stage whether its package will land with the candidates it wants. Where the hire is urgent or the business is not yet ready for a permanent appointment, we can also place interim and fractional C-suite leaders to cover the gap.

Further Reading and Authoritative Sources

For the UK tax rules that drive equity offers, HMRC’s guidance on Enterprise Management Incentives sets out the current company and individual limits, and the HMRC manual page on the EMI independence requirement explains why a UK subsidiary of another company cannot normally grant EMI options. The gov.uk page on Business Asset Disposal Relief gives the current rates and the conditions that apply to EMI shares.

For UK employment law, the text of the Employment Rights Act 2025 is on legislation.gov.uk. For US parent companies granting options, the IRS published the final regulations under section 409A of the Internal Revenue Code in Internal Revenue Bulletin 2007-19, which sets out the rules on option exercise prices and valuation of private company stock. None of these replaces specialist tax or legal advice on a specific plan, but they are the primary sources advisers work from.

The US VC Due Diligence Process and Senior Hiring

US VC firms carry out thorough people due diligence on the management team before investing and, after investment, before approving key senior hires. The process can be informal or highly structured. It typically involves reference conversations with former colleagues and employers, assessment by the VC’s own talent or people partners, and in some cases structured assessments from specialist executive evaluation firms. Senior executives joining US-VC backed businesses should expect more intensive pre-appointment scrutiny than they may have met in UK corporate or PE settings.

Network-based due diligence means a candidate’s reputation in the technology and scale-up community matters as much as the CV. US investors call contacts in the US and London technology communities to gather views on senior candidates before approving significant hires, and many of those calls happen without the candidate’s knowledge. Executives with a strong track record at comparable businesses will find this confirms their candidacy; those with mixed reputations, or who are less known in the scale-up community, may meet unexpected resistance late in the process.

For the hiring company, the practical implication is to involve the lead investor early. If an investor director is going to interview the final candidates or take back-channel references, it is better that this is built into the process timetable from the start than added after an offer has been discussed. Late investor vetoes are one of the more common reasons a senior search at a venture-backed business has to be restarted, and they are almost always avoidable with better sequencing.

Growth Stage Mismatches and Senior Hiring

One of the most consistent failures in US VC-backed UK senior hiring is the growth stage mismatch: appointing an executive who was excellent at one stage but is not equipped for the stage the business is entering. A VP Sales who was outstanding at finding the first customers is not necessarily the right person to build the repeatable enterprise sales motion that Series B scaling demands. A CFO who ran seed-stage finance well is not necessarily ready for the institutional investor relations and capital markets work of a business preparing for a Series C or a possible IPO.

Experienced US investors are alert to this. Many plan for management team change at each stage, expecting that some of the Series A team will not be the right people for Series B, and try to handle those transitions constructively rather than reactively. UK founders working with US investors for the first time sometimes find this approach brutal; understanding it as a structural feature of venture-backed growth makes it easier to manage.

The implication for hiring is that each appointment should be made for the stage the business is entering, not the stage it has just completed. The brief for a VP Sales at a business approaching Series B should describe the capabilities needed to build a scalable enterprise sales organisation — pipeline management, sales process design, hiring and managing a team, and developing enterprise relationships — rather than the qualities that made the previous commercial leader effective in the discovery phase.

The Board Observer and Investor Director Dynamic

US VC-backed UK businesses typically have several investor directors or board observers — partners or principals from the investing firms who attend board meetings and hold formal or informal governance roles. Managing relationships with multiple engaged investor directors, each with their own view of strategy, management performance and growth trajectory, is one of the most demanding parts of a senior role at a US-backed business.

The distinction between a director and an observer matters more than many executives realise. An investor director is a statutory director of the UK company with the duties that come with it; an observer attends but has no vote and no directors’ duties, though the investment documents may give the observer rights to information and to attend committees. Executives should understand which investors sit in which capacity, what reserved matters require investor consent under the shareholders’ agreement, and which decisions genuinely sit with management.

The CEO and CFO at a US VC-backed business typically spend considerably more time on investor relations than their counterparts at PE-backed or listed businesses of similar size. Frequent board meetings, regular investor calls and ad hoc engagement on specific questions create a governance relationship that is more demanding than a traditional UK board. Senior executives who do well here treat investor engagement as useful — the investors’ networks and operating experience are real resources. Those who find it intrusive will struggle regardless of their commercial ability.

International Expansion from a US VC Perspective

US VC investors often expect their UK portfolio companies to have international expansion, and particularly US market entry, on the roadmap within a few years of investment. That has direct hiring consequences: the commercial and product leadership team needs to be capable of managing international growth, not just UK growth. A VP Sales who has built a UK enterprise sales motion may or may not be the right person to lead US entry, because US enterprise sales involves different buyer expectations, competitive dynamics and relationship management.

US VCs with significant portfolio experience usually have firm views on US entry: whether to hire a US-based Head of US Sales reporting to the UK VP Sales, to relocate the UK VP Sales to the US, or to hire a separate US General Manager. These choices directly affect the UK leadership team’s scope and authority. They should be discussed openly at offer stage for any commercial leadership appointment at a business with near-term international plans, so the candidate knows whether the role will grow, shrink or move.

The reverse direction matters too. Where the business is a US company using the UK as its European base, the UK leadership team may be expected to open further European markets. In that case the brief needs to cover European experience as well as UK experience, and the hiring company should be clear about which decisions will be made in London and which in the US.

Common Mistakes at US VC-Backed UK Firms

1. Hiring from large corporates without scale-up experience. Senior executives from FTSE 100 companies or large professional services firms bring brand credibility but often lack the pace, operational flexibility and comfort with ambiguity that venture-backed growth businesses need. The best-performing senior hires at US VC-backed UK firms have usually spent a meaningful part of their careers in comparable growth-stage businesses.

2. Not resolving decision rights before offer. A common early failure at US VC-backed firms is an executive who joins without a clear understanding of what they are actually empowered to decide. Founding CEOs and active investor directors can constrain the new executive’s authority in ways that were never discussed during hiring. An explicit conversation about decision rights before offer prevents governance confusion after joining.

3. Under-explaining the equity value proposition. UK executives who are not used to equity-heavy packages frequently under-value the options they are offered — or, just as often, over-value them because nobody has explained the preference stack. Presenting a clear, evidence-based view of what the equity could be worth across a range of exit scenarios — base case, upside and downside — is essential when the candidate is weighing the package against a higher-salary alternative.

4. Ignoring cultural fit assessment. The governance and commercial culture of a US VC-backed business is genuinely different from UK corporate culture. Appointing commercially capable executives without assessing how they will adapt to the venture governance model, the speed of decision-making and the data-led management style consistently produces talented people who do not thrive.

5. Assuming US employment terms will transfer. US parent companies sometimes issue UK offer letters drafted on US assumptions, including at-will language and US-style severance arrangements. UK employment law does not work that way, and terms that ignore it create problems on both sides. The UK position is set out in a dedicated section below.

6. Leaving the share plan question until the end. Discovering at offer stage that EMI is not available, or that options will be over US parent shares with a different tax profile, can derail an otherwise agreed hire. The share plan position should be confirmed before the search starts.

The EMI Option Scheme and UK Tax Context

Enterprise Management Incentive (EMI) options are the main tax-advantaged equity incentive for UK employees at qualifying smaller companies. HMRC’s guidance on EMI share schemes sets the current limits: for options granted from 6 April 2026, a company can generally offer EMI if it has gross assets of £120 million or less and fewer than 500 full-time employees, up from £30 million and 250 employees previously. An individual can hold EMI options over shares worth up to £250,000 in a three-year period. The company must also carry on a qualifying trade, and some activities, such as banking, property development and legal services, are excluded.

The tax treatment is the reason EMI matters so much in offer negotiations. Where the option is granted at market value and the conditions are met, there is normally no income tax or National Insurance at grant or on exercise, and the growth in value is taxed as a capital gain on sale. EMI shares can also qualify for Business Asset Disposal Relief, provided the option was granted at least two years before the sale. The rate of relief has risen: according to the gov.uk guidance on Business Asset Disposal Relief, it is 18% for disposals from 6 April 2026, compared with 14% in 2025/26 and 10% before that. Older material quoting a 10% rate is out of date.

The critical point for US-VC backed businesses is the independence requirement. Under HMRC’s manual on the EMI independence requirement, the company granting the options must not be a 51% subsidiary of another company, or under the control of another company (together with persons connected with it), and there must be no arrangements in place by which it could become so. A UK operating company that sits beneath a US parent therefore cannot grant EMI options over its own shares. Where the structure is a UK company with US VC investors holding minority stakes and no single company in control, EMI may well be available, subject to the other tests.

As businesses grow through Series B, C and beyond, they may also outgrow the gross assets or employee limits. The higher thresholds from April 2026 mean more scale-ups now stay within EMI for longer, but the transition to non-tax-advantaged options, a CSOP or a long-term incentive plan still needs planning ahead of time, both to keep the incentive programme effective and to manage the tax position of existing option holders. The CFO and General Counsel at a scaling business should track the qualifying conditions before each funding round rather than discovering a disqualification after the event.

US Parent Stock Options for UK Employees

Where a US parent sits above the UK business, UK employees are usually granted options under the parent’s US equity plan. Because the UK subsidiary fails the EMI independence test, those options are most often unapproved (non-tax-advantaged) options from a UK perspective. In broad terms, that means income tax, and National Insurance where the shares are readily convertible assets, on the difference between the market value and the exercise price when the option is exercised, rather than capital gains treatment on the whole growth in value. For a senior executive weighing an offer, this difference can be significant, and it should be explained before the offer is made.

There are alternatives. A Company Share Option Plan (CSOP) is a UK tax-advantaged scheme with a lower individual limit than EMI. HMRC’s CSOP rules prevent the use of shares in an unlisted company that is under the control of another company, so a UK subsidiary cannot use its own shares, but a US parent that is not itself controlled by another company may be able to operate a CSOP over its own shares for its UK employees, typically through a UK sub-plan. Whether this works depends on the parent’s ownership, its share classes and the plan terms, and it needs specialist advice. Some US parents also adopt UK sub-plans to their main plan simply to make the UK tax treatment and reporting clear, even where the options are unapproved.

The US side has its own rules. Options granted by a US company are subject to section 409A of the Internal Revenue Code, which treats certain discounted options as deferred compensation. Under the final 409A regulations published in Internal Revenue Bulletin 2007-19, an option generally falls outside 409A if its exercise price is never less than the fair market value of the underlying stock at grant. For private companies, the regulations give a presumption of reasonableness to valuations based on an independent appraisal, among other methods, which is why US-backed businesses commission regular “409A valuations”. A 409A value is a US tax valuation; it is not the same as a UK market value agreed with HMRC for EMI or CSOP purposes, and the two can differ. UK candidates who are not US taxpayers are not usually caught by 409A personally, but the plan will still be run to US standards, and any candidate who is a US citizen or green card holder needs separate US tax advice.

Practical points for the hiring company: confirm which entity grants the options, whether a UK sub-plan exists, how the UK tax will be collected through payroll on exercise, what happens to unvested options on leaving, and whether the plan allows exercise only on an exit. These are exactly the questions an experienced UK senior candidate’s adviser will raise, and having the answers ready makes the offer more credible.

UK Employment Law Differences US Investors Should Know

US investors and US parent companies used to at-will employment sometimes underestimate how different the UK position is. UK employees have a statutory right to minimum notice, and senior executive contracts usually set notice periods well above the statutory minimum, often with garden leave and payment in lieu of notice clauses. Notice periods matter on both sides of a hire: the candidate’s current notice determines how soon they can start, and the notice in the new contract shapes how easily the company can make a change later.

The Employment Rights Act 2025, which received Royal Assent on 18 December 2025, changes several things that matter for senior hiring. It reduces the qualifying period for ordinary unfair dismissal claims from two years to six months, with the government indicating that the change will apply from 1 January 2027, and it removes the cap on the compensatory award for unfair dismissal. Together those changes mean that a senior executive dismissed after a relatively short period may have a claim that is not capped in the way it used to be. The Act is being brought into force in stages, so the timing of each measure should be checked against the current government implementation timetable rather than assumed.

For US-backed businesses, the practical consequences are straightforward. Offer letters and service agreements for UK executives should be drafted under English law by UK employment lawyers, not adapted from a US template. Probation periods, performance management and exit processes need to be run properly from the start. And the decision to part company with an executive who is not working out should be made and handled carefully, because the cost of getting it wrong has risen. None of this should discourage a US-backed business from hiring in the UK; it simply needs to be built into the plan.

Restrictive covenants are another area where US assumptions do not transfer. Post-termination non-compete restrictions in the UK are enforceable only where they protect a legitimate business interest and go no further than reasonably necessary. Covenants drafted for a US contract should be reviewed by UK advisers before they are used, and kept under review as the law develops.

Exec Capital’s Scale-Up Senior Hiring Practice

Exec Capital runs senior executive searches for US VC-backed UK businesses at every stage from Series A to pre-IPO. The practice combines relationships across the UK technology, fintech and SaaS leadership community with a working knowledge of US venture governance and the equity structures that shape offers. We work directly with founders, CEOs and investor directors to design search processes that reflect the growth stage and the culture of each business, and our scale-up executive search team handles the full range of senior roles from CFO and CRO to UK Managing Director.

Exec Capital is part of FD Capital Group. Our sister firm FD Capital specialises in fractional, interim and permanent CFO and finance director placements, which complements the broader C-suite work we do for venture-backed businesses. For businesses backed by European rather than US investors, the dynamics are similar in some respects and different in others, and we cover that variant in a companion guide.

From Series B to Series D: How Requirements Change

Senior leadership requirements at a US VC-backed UK business change materially at each stage, and a team that is right for Series B will usually need to evolve by Series D. At Series B, the main challenge is building repeatable commercial and operational processes on the product-market fit that earlier funding validated. At Series C, the focus shifts to scaling those processes internationally and building the organisational infrastructure for a business operating across several markets. By Series D, the company is approaching the scale and governance complexity of a pre-IPO business, and the senior team needs the institutional management capability to handle that transition.

The most common failure is not appointing the wrong person but failing to plan for the stage transitions that will make the current appointment insufficient. A VP Sales hired at Series B who is excellent at building the UK sales playbook will not necessarily be the right Chief Revenue Officer when the business needs to run a pan-European sales organisation. Planning for that — through development of the existing leader or a structured succession plan — is part of the hiring strategy from Series B, not a reactive decision at Series C when the gap becomes obvious.

US VC investors think explicitly about these transitions and have seen across their portfolios where management changes tend to be needed. Founders and CEOs who ask their investors directly which senior roles they have seen need to change at Series C and D are drawing on a useful source of experience that sits on their own board.

US VC-backed UK businesses at Series C and beyond also need to think about their US go-to-market strategy, and the hiring implications are significant. Building a US team, whether a US Head of Sales reporting to the UK CRO or a more autonomous US General Manager, requires a different search process from UK hiring. The US technology talent market operates differently: pay expectations, equity conventions and assessment practices all vary, and employment law works on different principles. UK founders expanding into the US for the first time should work with advisers who have direct US hiring experience rather than assuming their UK process will transfer unchanged.

The equity position also changes by stage. Early option grants at a low strike price are generous in percentage terms; later grants are smaller percentages of a more valuable company, with a higher strike price and more preference shares ahead of them. Senior hires joining at Series C or D will compare their grant with what earlier joiners received, and the company should be ready to explain how the later grant has been sized and what it could be worth.

Frequently asked questions

Can a UK subsidiary of a US company grant EMI options?

Generally not. The EMI independence requirement means the company granting the options must not be a 51% subsidiary of, or controlled by, another company. A UK operating company beneath a US parent fails that test, so options over its own shares cannot be EMI options. Specialist advice is needed on whether any alternative structure works.

What tax do UK employees pay on US parent company options?

Where the options are not tax-advantaged, UK employees are usually liable to income tax on the gain at exercise, with National Insurance where the shares are readily convertible assets. A CSOP over the parent’s shares may be possible in some structures. The detail depends on the plan and the employee’s circumstances.

What is a 409A valuation and does it matter to UK candidates?

A 409A valuation is a US tax valuation used to set the exercise price of options granted by a US company so they fall outside section 409A. It is not the same as a UK market value for EMI or CSOP purposes. UK candidates should understand which valuation underlies their strike price, and US taxpayers need separate advice.

How does the Employment Rights Act 2025 affect senior hires?

The Act reduces the qualifying period for ordinary unfair dismissal claims to six months, which the government has indicated will apply from 1 January 2027, and removes the cap on the compensatory award. Senior contracts and exit processes should be drafted and managed with that in mind.

Should a US-VC backed UK firm hire from the scale-up market or from corporates?

Usually from the scale-up market for operating roles, because pace and governance culture are the most common causes of early failure. Corporate candidates can succeed, but they need careful assessment of how they will adapt to an active investor board and an equity-heavy package.