SolvedETASSUM53010 | Enterprise Management Incentives (EMI): Eligible employees: Employment requirement
From HM Revenue & Customs · Employee Tax Advantaged Share Scheme User Manual
Paragraph 25, Schedule 5 of the Income Tax (Earnings and Pensions) Act 2003 (ITEPA)
Individuals are only eligible for EMI options if they are employees of the company whose shares are the subject of the options, or, in the case of a group, employees of any qualifying subsidiary of that company.
Directors are classed as employees of a company, and so as long as directors meet the criteria set out for employees they will also qualify for EMI.