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Mobility Matters

Considerations for Operating a Global Employee Stock Purchase Plan

November 2025 | By Ryan Borgmann, KPMG LLP (U.S.) and Lorna Jordan, KPMG LLP (U.K.) 

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In today’s competitive talent market, Employee Stock Purchase Plans (ESPPs) are one approach multinational companies may consider to support talent attraction and retention across global markets. However, offering ESPPs outside the United States introduces a complex landscape of tax, legal, and compliance considerations. Below are key areas that leaders should evaluate before implementing a global ESPP.

What to watch: Critical considerations for global ESPPs

1

Securities Compliance: Organizations may need to register plans, comply with applicable disclosure requirements, and consider ownership thresholds and insider trading regulations based on local laws.

2

Tax Strategy: It is important to assess tax implications related to purchase and sale events, support payroll reporting needs, and offer country-specific tax guidance where feasible.

3

Labor Regulations: Programs should aim to support non-discriminatory practices, informed employee participation, and alignment with local employment regulations.

4

Data Privacy: Considerations may include compliance with frameworks such as GDPR, PIPEDA, and PDPA. Organizations should seek appropriate consent and evaluate cross-border data transfer protocols.

5

Currency Controls: Companies may need to plan for potential currency conversion restrictions, fund transfer limitations, and exchange rate fluctuations.

6

Administration: Efforts to integrate payroll systems, facilitate clear communication, and encourage participant feedback can help improve program engagement.

Designing a compliant, attractive ESPP

Effective plan design plays a critical role in supporting the success of global ESPPs. Considerations include defining eligibility criteria, aligning offering periods with local practices, setting meaningful discounts, and managing purchase limits to balance risk and participation.

Dive into our thinking:

Considerations for Operating a Global Employee Stock Purchase Plan

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Mobility Matters

Mobility Matters, published by KPMG's Global Mobility Services (GMS) practice, offers thought-provoking articles that can help raise awareness about topical and timely issues affecting international assignment programs and globally-mobile employees working for multinational organizations.

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Ryan M. Borgmann
Senior Manager, Global Reward Services, KPMG US
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Image of Ryan M. Borgmann
Ryan M. Borgmann
Senior Manager, Global Reward Services, KPMG US
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