Fact-checked by Grok 2 weeks ago

P11D

The P11D is a statutory form mandated by His Majesty's Revenue and Customs (HMRC) in the United Kingdom, requiring employers to report taxable benefits in kind—such as company cars, private medical insurance, interest-free loans, and accommodation—and certain expenses provided to employees and directors that are not processed through the Pay As You Earn (PAYE) payroll system. This annual declaration ensures HMRC can assess and collect appropriate income tax and National Insurance contributions on these non-cash perks, which are treated as part of an individual's taxable income. Employers must submit a separate P11D form for each qualifying employee or director, detailing the monetary value of benefits using HMRC-approved valuation methods, while the accompanying P11D(b) form summarizes the total Class 1A National Insurance liability owed by the employer. Introduced as part of the UK's employment framework, the P11D system applies to all UK-based employers, covering benefits extended not only to staff but also to their family members or household if relevant, with exemptions for trivial items under £50 or benefits already taxed via under optional remuneration arrangements like salary sacrifice schemes. Key sections of the P11D include reporting on assets transferred (e.g., gifts of goods), cars and fuel provided for private use, vouchers or credit cards, medical treatment abroad, and relocation expenses exceeding £8,000, all of which must include full (VAT) amounts even if irrecoverable. Submissions are filed online through HMRC's PAYE Online service or , with employers required to provide copies of the P11D to affected individuals by the same deadline to facilitate their personal returns. For the 2024 to 2025 tax year, the deadline for submitting P11D and P11D(b) forms is 6 July 2025, alongside payment of any Class 1A National Insurance due by 19 July 2025 (or 22 July if paid electronically). Failure to comply can result in penalties for late submission of the P11D(b) of £100 for each 50 employees for each month or part month late, or up to £3,000 per form for inaccuracies, underscoring the form's role in maintaining compliance within the broader expenses and benefits reporting regime.

Introduction

Definition and Purpose

The P11D form is an annual declaration submitted by employers to His Majesty's Revenue and Customs (HMRC) for reporting benefits in kind (BiKs), such as company cars or private medical insurance, and certain non-reimbursed expenses provided to employees and directors that are not processed through the standard Pay As You Earn (PAYE) system. These items represent additional value given to staff beyond regular salary, requiring separate disclosure to ensure accurate taxation. The primary purpose of the P11D is to facilitate HMRC's assessment and collection of and Class 1A contributions (NICs) on these non-cash benefits and expenses, thereby promoting equitable taxation by capturing remuneration forms that might otherwise evade deductions. Introduced in as part of the initial PAYE regulations following to address , the form has served as a key mechanism for transparency in employer-provided advantages. From April 2026, payrolling of most benefits will become mandatory, altering traditional P11D reporting requirements. This reporting helps prevent under-taxation and supports HMRC in adjusting employees' tax codes or enabling adjustments. The P11D applies to all employers, irrespective of business size, who provide qualifying BiKs or expenses to employees or directors during the tax year, with submissions required for each relevant individual unless the benefits are already taxed via . While there is no overarching de minimis threshold mandating non-reporting of minor items, specific exemptions exist for trivial benefits valued at £50 or less and incidental expenses up to £5 per night in the (or £10 overseas), allowing employers to exclude such low-value provisions from declaration.

Scope and Applicability

P11D reporting obligations apply to all UK-based employers, including companies, partnerships, and public bodies, who must submit the form for any employees or directors receiving taxable (BiKs) or non-reimbursed expenses during the year. This requirement extends to non-UK employers if they provide such items to individuals with UK-taxable employment, ensuring that and contributions on these perks are properly assessed. The individuals covered include full-time and part-time employees, as well as directors—whether or non-executive—who receive reportable items, along with their members, spouses, civil partners, or members if benefits are extended to them. Self-employed individuals and independent contractors are generally excluded from P11D requirements, unless their status is reclassified as employees under employment law or rules, in which case becomes mandatory. Reporting is required for any tax year running from 6 to 5 where taxable BiKs or expenses are provided that are not processed through or covered by a PAYE Settlement Agreement, particularly if they surpass trivial levels—such as one-off non-cash gifts costing £50 or less that are not linked to performance, or up to £300 annually for directors of close companies. Examples triggering applicability include provision of company cars or private , as these constitute taxable benefits unless exempt. There is no aggregate monetary threshold for filing; instead, each qualifying item must be reported individually if it meets the criteria for BiKs or unreimbursed business expenses.

History and Evolution

Origins and Development

The reporting of benefits (BiK) in the UK originated with the of the benefits code under Schedule E of the Income Tax Act 1952, enacted via the Finance Act 1948, which established a £2,000 earnings threshold for taxing non-cash perks provided to higher-paid employees and directors amid the post-World War II expansion of corporate benefits packages. This framework addressed gaps in the existing PAYE system, introduced in 1944, by requiring employers to declare certain perquisites not captured through standard payroll deductions. The P11D form itself emerged in the early as a dedicated tool within the PAYE regime to facilitate annual submissions of such benefits for directors and employees above the threshold, replacing reporting methods and aligning with the growing administrative needs of the tax authority. A pivotal advancement occurred with the Finance Act 1976, which significantly broadened the scope of taxable BiK by mandating reporting on private use of company cars, beneficial loans (with a de minimis allowance of £50), and the provision of tangible movable assets valued at 10% of their market cost, thereby extending obligations beyond directors to a wider class of employees. This legislation responded to increasing tax avoidance through non-cash remuneration, raising the higher-paid threshold to £8,500 by 1979 and formalizing the distinction between P11D returns for those above the threshold and the complementary P9D form for lower-paid staff below it. Early iterations of these forms, evolving from the 1948 code, emphasized conceptual valuation over exhaustive detail, though administrative burdens were evident from the outset, prompting HMRC to issue simplified guidance in the 1980s to mitigate compliance complexities. During the 1990s, the system underwent further refinement, including the introduction of Class 1A contributions in 1991 specifically for car and fuel benefits, which integrated employer liabilities into the P11D(b) summary form and expanded reportable expense types without overhauling the core structure. The (Earnings and Pensions) Act 2003 represented a comprehensive codification of BiK rules, standardizing valuation methods and reporting requirements under Chapters 2 to 11 while preserving the P11D's role in the PAYE ecosystem. Prior to 2016, HMRC piloted voluntary payrolling options with large employers around 2013, testing real-time inclusion of BiK in to alleviate year-end filing pressures, though the P11D remained the default mechanism. These developments underscored a gradual shift toward streamlined administration while maintaining focus on equitable taxation of non-monetary compensation.

Key Legislative Changes

The Income Tax (Earnings and Pensions) Act 2003 (ITEPA 2003) represented a major consolidation of the taxation rules for benefits in kind (BiK), bringing them under Part 3, Chapters 2 to 11, which form the core of the benefits code. This restructuring mandated the reporting of specific items, including living accommodation under Chapter 10 and non-cash vouchers under Chapter 4, via form P11D to ensure accurate assessment. Furthermore, ITEPA 2003 introduced standardized cash equivalent formulas for company cars (based on list price and CO2 emissions) and fuel benefits under Chapter 6, providing a consistent basis for valuation and taxation. The Finance Act 2016 introduced the option for voluntary payrolling of BiKs starting from the 2016/17 tax year, enabling employers to report and deduct tax on benefits through real-time payroll submissions rather than end-of-year P11D forms. This reform reduced administrative burdens for participating employers by integrating BiK taxation into regular payroll processes, though it required prior registration with HMRC and compatible software. In the , legislative updates addressed pandemic-related needs, including temporary exemptions for equipment provided or reimbursed between 16 and 5 April 2022 under the (Exemption for Related Home Office Expenses) Regulations . These measures allowed tax-free provision of items like desks and computers solely for work use, bypassing P11D reporting during the period. HMRC confirmed in April 2025 a delay to the mandatory payrolling of BiKs, shifting implementation from April 2026 to April 2027 following feedback on system readiness. For the 2025/26 year, P11D remains mandatory for non-payrolled benefits, with HMRC's updated guidance in September 2025 reinforcing the requirement for digital submissions via the PAYE online service. A phase-out of most P11D filings is planned after the 2026/27 year, once mandatory payrolling takes full effect. These changes collectively aim to simplify by modernizing reporting mechanisms, minimizing end-of-year paperwork, and aligning BiK taxation with real-time systems, ultimately reducing errors and administrative costs for employers.

Reportable Items

Benefits in Kind

Benefits in kind (BiKs), also known as non-cash benefits, are goods or services provided to employees or directors (or their family members) by reason of their , which are treated as under section 62 of the (Earnings and Pensions) Act 2003 (ITEPA 2003). These benefits have a monetary value and are subject to and contributions, distinct from salary or wages. The primary categories of BiKs requiring P11D reporting include company cars (with fuel and private use), private medical , interest-free or low-interest loans, employer-provided living accommodation, school fees, vouchers or cards, assets transferred to the employee (e.g., gifts of goods, valued at the cost to the employer including ), private medical or dental (including abroad, exempt only if the need arose during overseas ), and services supplied (e.g., employer-paid subscriptions). For company cars, the benefit arises from private use, valued based on the vehicle's CO2 emissions and method, while fuel provided for private mileage adds a separate charge. Private medical typically covers or premiums for the employee and their members, making the full cost reportable if provided through the employer. Interest-free or low-interest loans create a taxable calculated on the forgone , applicable to borrowings from the employer. Employer-provided living accommodation is assessed using the property's market rental value or other statutory measures to determine the cash equivalent. School fees paid by the employer for an employee's are fully reportable as a , with the employer liable for Class 1A on the cost. Vouchers and cards, such as those for or , are valued at their cost to the employer and reported if provided for use. All BiKs must be reported on form P11D unless exempt or processed through payrolling benefits (PBIK), where the value is included in for real-time . Exemptions include trivial benefits costing £50 or less per item, provided they are not cash, not part of a contractual , and not given as rewards for performance; for directors of close companies (and their family or household), the total value of such exempt benefits is limited to £300 per tax year. A single (or one ) provided by is exempt from reporting, regardless of private use, if the phone contract is between and the supplier and there is no transfer of in the to the employee. Providing multiple phones or transferring ownership may require reporting the benefit.

Expenses and Allowances

Expenses and allowances refer to cash payments, reimbursements, or allowances provided by employers to employees or directors for expenses that do not qualify as wholly business-related under HMRC exemptions, making them taxable and reportable on form P11D. These items are distinct from , focusing on monetary or reimbursement-based support rather than non-cash perks, though some hybrid payments may overlap briefly with benefit valuations. Reportable expenses arise when payments exceed statutory exemptions, lack supporting such as receipts, or do not qualify for specific reliefs like or subsistence. Key reportable types include non-business travel allowances, where employers reimburse personal commuting or leisure journeys without business justification, rendering the full amount taxable. Entertainment expenses become reportable if they cover or non-business , such as meals or events not linked to client or supplier relations, particularly for directors where private hospitality lacks a nexus. Relocation costs exceeding the £8,000 exemption limit—applicable to qualifying moves for a new job—are taxable on the excess, covering items like temporary housing or removal fees beyond the threshold. or allowances are reportable if the items are not exclusively for work purposes, such as everyday attire rather than protective gear or branded uniforms that identify the employer. Specific reporting rules require inclusion on P11D if reimbursements lack receipts to verify use or surpass approved rates, ensuring only non-deductible portions are captured. For instance, mileage allowances using personal vehicles are exempt up to HMRC's statutory rates of 45 pence per mile for the first 10,000 miles and 25 pence thereafter for cars and vans in the 2025/26 tax year; any excess payment is reportable as a taxable . Director-specific items, such as private hospitality reimbursements without evidence, face heightened scrutiny and must be reported at their full cost, including where applicable. HMRC exemptions replace the former dispensation system, allowing qualifying business expenses—like substantiated travel or tools—to be excluded from P11D reporting without annual applications for standard cases. Employers can apply for bespoke exemption agreements for unique expense types, verified through records like receipts, to avoid reporting administrative burdens on approved business costs. This framework ensures only non-exempt portions contribute to employees' taxable income, with employers responsible for Class 1A National Insurance on reported values.

Valuation and Calculation

Methods for Valuing Benefits

The valuation of benefits (BiKs) and certain expenses for P11D reporting follows the principle of determining a "cash equivalent" value, as defined under Part 3 of the Income Tax (Earnings and Pensions) Act 2003 (ITEPA 2003), which represents either the expense incurred by the employer in providing the benefit or its if no direct cost is borne by the employer. This approach ensures a standardized monetary assessment of non-cash perks, such as company cars or subsidized loans, to facilitate accurate tax reporting. For company cars, the cash equivalent is calculated as the vehicle's list price at first registration (including delivery charges, taxes, and accessories fitted at that time) multiplied by an "appropriate percentage" derived from its CO2 emissions. For the 2025/26 tax year, the appropriate percentage for plug-in hybrids (1-50 g/km CO2) ranges from 3% (130+ miles electric range) to 15% (<30 miles), while for other cars it starts at 16% for 51-54 g/km and increases by 1% per 5 g/km band up to 37%; zero-emission electric vehicles qualify for a reduced rate of 3%. Fuel benefits are valued separately by applying the same appropriate percentage to a fixed multiplier of £28,200, representing the notional cost of private fuel provision. Beneficial loans, where interest is charged below the market rate, are valued using the difference between the HMRC official rate of interest and the actual rate charged. For the 2025/26 tax year, the official rate is 3.75%, effective from 6 April 2025. The cash equivalent is computed as: (official\ rate - actual\ rate) \times loan\ amount \times \frac{days\ outstanding}{365} This formula prorates the benefit for the period the loan is available, assuming a 365-day year. Living accommodation provided by the employer is valued at the higher of the rent paid by the employer or the property's open market rental value, determined as the amount a willing tenant would pay a willing landlord under normal market conditions. The "annual value" may also apply if lower, based on the property's rateable value or a professional assessment, but additional charges arise if the employer's total expenditure exceeds £75,000 in the tax year. Expenses and allowances subject to P11D reporting, such as reimbursements for private travel or asset use, are valued at the actual amount reimbursed or provided, reduced by the proportion attributable to use. For instance, if an asset like a is used 80% for private purposes, 80% of its cost forms the taxable cash equivalent after deducting any employee contributions. Employers must maintain contemporaneous records, such as mileage logs or usage diaries, to substantiate these /private apportionments. HMRC provides online calculators to assist with valuations, particularly for and fuel benefits, which incorporate the latest CO2 data and tax year rates; these tools are updated annually to reflect legislative changes. P11D working sheets for accommodation, loans, and other items are also available to guide manual calculations and ensure compliance.

Determining Taxable Amounts

The taxable amount for benefits in kind (BiKs) and expenses reported on form P11D is calculated as the cash equivalent value—derived from the relevant valuation method—minus any contributions made by the employee towards the benefit. This net amount is then added to the employee's employment income as part of the year-end adjustment, ensuring it forms part of their total taxable earnings for the year. Employers are liable for Class 1A National Insurance Contributions (NICs) on the taxable value of BiKs and certain expenses, calculated at a rate of 15% for the 2025/26 tax year. These contributions apply to the full taxable amount after employee deductions and are paid by the employer via form P11D(b), with no Class 1B NICs arising unless the benefits are handled through a PAYE Settlement Agreement (PSA). If BiKs are —taxed through the in —no P11D is required for those items, avoiding , though Class 1A NICs must still be calculated and reported on P11D(b). Adjustments to the taxable amount may reduce liability where benefits include a business-use element; for instance, if an employee undertakes significant business mileage, the car benefit can be proportionately reduced based on the restricted private use, such as applying a 20% business mileage factor to lower the cash equivalent. Similarly, qualifying mileage allowances paid by employers are exempt up to 45 pence per mile for the first 10,000 business miles (cars or vans) and 25 pence thereafter, with any excess treated as taxable earnings. For example, a benefit valued at £5,000 combined with £500 in taxable expenses yields a total taxable amount of £5,500 after any employee contributions; the employer then pays 1A NICs of £825 (15% of £5,500).

Filing and Reporting Process

Deadlines and Requirements

The P11D forms must be submitted to HMRC by 6 July following the end of the relevant tax year, which spans from 6 April to 5 April. For example, P11D forms covering the 2025/26 tax year must be filed by 6 July 2026. Employers must prepare one P11D form for each employee or director who received reportable benefits in kind or expenses during the tax year, along with a single P11D(b) form summarizing the employer's total Class 1A National Insurance liability on those items. Supporting records, including working sheets used to calculate values, must be retained for three years from the end of the tax year to which they relate, to demonstrate compliance if queried by HMRC. To meet these requirements, employers must first gather comprehensive data on all relevant benefits and expenses provided from 6 April to 5 April, ensuring accuracy in valuation and eligibility for reporting. By 6 July, employers are obligated to notify each affected employee or director of the details included on their individual P11D, typically by providing a copy of the form or equivalent information. Where applicable, employers may rely on HMRC's statutory exemptions for qualifying employment-related expenses, which eliminate the need to report those items on the P11D. For submissions in 2025 and beyond, digital filing is mandatory for all employers; paper forms are no longer accepted.

Submission Procedures

Employers in the are required to submit P11D forms electronically to (HMRC) to report taxable benefits in kind and certain expenses provided to employees and directors. As of the 2023/24 tax year, paper submissions are no longer accepted, with all filings mandated to be completed online either through HMRC's free PAYE Online service or via compatible commercial payroll software. The PAYE Online service is particularly suitable for employers with fewer than 500 employees, while larger organizations typically integrate submissions through certified software that connects directly to HMRC systems. The submission process begins with ensuring the employer is registered for PAYE Online if using that method; registration is straightforward and requires Government Gateway credentials, which can be obtained via HMRC's online portal if not already held. Once logged in, employers access the dedicated P11D workspace within PAYE Online, where they select the relevant tax year and begin entering data for each applicable employee. For each P11D form, details such as the employee's name, National Insurance number, and address are inputted, followed by the taxable values categorized under specific section codes for various benefits in kind and expenses (sections A through M; e.g., A for cars and fuel, D for loans, I for vouchers and credit cards). After completing individual P11D forms, employers generate the accompanying P11D(b) form, which aggregates totals for Class 1A National Insurance contributions (NICs) owed across all employees, including a summary list of those with reportable items. The entire set of forms is then reviewed for accuracy and submitted electronically in one batch. No supporting documents or attachments, such as receipts or working sheets, are required to be submitted with the P11D forms; however, employers must maintain internal records, including evidence like mileage logs for fuel benefits or valuation documents for assets, for at least three years after the end of the tax year in question to substantiate the reported figures in case of HMRC review. Additionally, a copy of the completed form must be provided to each relevant employee or , typically by the same deadline as the HMRC submission, to inform them of the reported benefits for their personal tax records. Following successful submission, HMRC processes the P11D data to automatically adjust employees' tax codes for the subsequent year, ensuring any additional due on the benefits is collected through deductions where possible. Employers are then responsible for paying the calculated Class 1A NICs, which become due by 22 following the end of the relevant year (or 19 if paid by post, though electronic payment is standard); this can be done via the employer's usual PAYE payment channels, such as or linked to their HMRC account. Submissions must be completed by 6 after the tax year-end to avoid penalties.

Tax Implications

For Employees

The values of benefits in kind (BiK) and certain expenses reported on form P11D are treated as additional taxable employment income for employees, increasing their overall income subject to income tax and potentially affecting their tax band or personal allowances. HM Revenue and Customs (HMRC) uses this information to adjust the employee's PAYE tax code for the following tax year, ensuring the correct amount of tax is deducted at source, or to issue a Simple Assessment if underpaid tax from the previous year needs to be collected—typically for amounts up to £3,000, though self-assessment may be required if the underpayment exceeds £3,000 or the taxpayer meets other filing criteria, such as having multiple untaxed income sources. Employees have the right to receive a copy of their P11D form from their employer by 6 July following the end of the relevant year, which details the taxable value of each reported or ; this allows them to verify the information and prepare for any adjustments. If the is payrolled through the employee's , can be deducted directly via , but for non-payrolled items reported on P11D, the is collected by HMRC via adjustment to the employee's tax code, Simple Assessment, or . Additionally, if National Insurance contributions (NICs) have been overpaid due to adjustments related to reported —such as through payrolling—employees can claim relief by contacting HMRC directly or through . These P11D-reported items can have significant financial impacts on employees; for instance, a £3,000 BiK added to a basic rate taxpayer's income near the £50,270 higher rate threshold could push them into the 40% , resulting in an additional £600 in liability (based on the 20% difference on that amount). Such additions to adjusted may also trigger the high-income charge, where families with income over £60,000 face a 1% withdrawal per £200 above the threshold, potentially leading to full repayment of for incomes exceeding £80,000. As of 2025, the increasing adoption of voluntary payrolling for BiK—where benefits are taxed in real-time through payroll—reduces year-end surprises for employees by spreading tax deductions evenly, though non-payrolled items continue to result in potential year-end tax bills via P11D adjustments. Mandatory payrolling is set for April 2027, further minimizing such disruptions.

For Employers

Employers are responsible for paying Class 1A National Insurance contributions (NICs) on the taxable value of benefits in kind (BiKs) and certain expenses reported via form P11D, at a rate of 15% for the 2025 to 2026 tax year. This liability applies solely to the employer, with no corresponding NIC deduction from employees for BiKs, as the employer covers the full amount. The Class 1A NIC is calculated on the cash equivalent values detailed in the P11D forms and must be paid by 22 July following the end of the tax year (or 19 July if paying by post). In addition to financial obligations, employers have several administrative duties related to P11D reporting. These include maintaining detailed records of all expenses, benefits, and facilities provided to employees and directors, such as vouchers, receipts, and valuations, to support the accuracy of submissions. Employers must provide a copy of each completed P11D form to the relevant employee or director by the filing deadline and certain exemptions apply to trivial or non-taxable items (such as benefits costing £50 or less per instance, up to £300 annually), which do not need to be reported on P11D. Where applicable, employers may reclaim input VAT on the costs of providing BiKs, provided the expenses qualify as business-related and VAT records are kept, even though the full VAT-inclusive amount is included in P11D valuations. The overall cost burden for employers encompasses both the Class 1A NIC payments and administrative efforts, with businesses typically spending an average of 5 hours per P11D submission, translating to an estimated £200-500 annually per employee depending on complexity and internal resources. through offers an incentive by eliminating the need for separate P11D filings, thereby reducing dual reporting and streamlining processes. To manage risks, employers should ensure robust documentation, as HMRC compliance checks may reclassify reported items—such as non-business expenses as taxable BiKs—potentially resulting in backdated Class 1A liabilities and interest.

Alternatives and Exemptions

Payrolling Benefits in Kind

Payrolling benefits in kind (BiK) refers to the process of reporting and taxing through real-time submissions to HMRC, rather than via year-end P11D forms. This voluntary option was introduced for the 2016/17 year, allowing employers to integrate the cash equivalent value of most BiKs directly into Full Payment Submissions (FPS) under the Real Time Information (RTI) system. The operational process begins with employer registration through HMRC's online service before the start of the tax year, after which the annual taxable value of each BiK is divided by the number of pay periods and reported monthly via —for example, a £5,200 annual benefit would be apportioned as approximately £433 per month over 12 periods. HMRC then reviews these submissions and adjusts employees' codes as necessary to ensure accurate collection on the benefits without , spreading the liability across the year rather than retrospectively. No P11D form is required for items successfully payrolled in this manner, though employers must still submit a P11D(b) for 1A Contributions (NICs) on those benefits. This method offers several advantages, including reduced administrative burden from eliminating P11D preparation and filing, as well as avoiding unexpected year-end tax bills for employees by collecting incrementally through . It also enables and minimizes errors associated with post-year-end . Payrolling became mandatory for most BiKs from 6 April 2027, following a delay from the original 2026 date as announced by HMRC in 2025 to allow additional preparation time. As of 2025, HMRC continues to encourage voluntary adoption to facilitate a smoother transition, with employers needing to update software to handle Class 1A reporting and payments. Certain items, such as employee expenses, remain reportable via P11D until the full phase-out of the form for applicable categories in 2027.

PAYE Settlement Agreements and Exemptions

PAYE Settlement Agreements (PSAs) provide employers with a voluntary to settle and contributions (NICs) on certain minor, irregular, or impracticable benefits (BiKs) and expenses payments through a single annual payment to HMRC, thereby avoiding the need to report these items on individual P11D forms for affected employees. Under a PSA, the employer assumes liability for the due at the employees' marginal rates and Class 1B NICs at the prevailing rate of 15% for the 2025-26 year, calculated on a grossed-up basis to account for the and NICs treated as . This arrangement simplifies for items that are difficult to apportion or value precisely, such as minor taxable relocation expenses exceeding statutory limits or irregular taxable gifts over £50. To establish a PSA, employers must apply to HMRC by 5 July following the end of the relevant year, detailing the types of expenses and benefits to be included; HMRC reviews and approves the annually, which can be renewed or varied as needed. Payments under the PSA are due by 22 after the end of the tax year (or 19 October for payments), and the agreement cannot cover major or regular benefits such as company cars, , or living accommodation, which must be reported via P11D or payrolled. Once in place, items settled through the PSA are not subject to employee reporting or adjustment via , promoting administrative efficiency for low-value items. In addition to PSAs, certain statutory exemptions under the (Earnings and Pensions) 2003 (ITEPA) relieve employers from reporting specific BiKs and expenses on P11D forms, as these are not treated as taxable earnings. Key exemptions include:
  • Workplace parking: Provision of , , or bicycle parking facilities at or near the employee's workplace, under section 237 ITEPA.
  • Annual eye tests: Reimbursement of costs for eye examinations and special corrective appliances needed for work with visual screens, limited to one test per year under section 320A ITEPA.
  • Mobile phones: Supply or reimbursement of one private per employee (including calls and data), provided exclusively for business use initially but allowing private use, under section 319 ITEPA.
  • Long-service awards: Non-cash vouchers or benefits for personal use awarded for at least 20 years' service, capped at £50 in value under section 323 ITEPA.
  • related home working: Until 5 April 2022, reimbursements for additional household expenses (such as gas, electricity, or broadband) incurred due to mandatory home working under restrictions were exempt, with selective extensions for equipment purchases; post-2022, standard home working exemptions apply only to incidental costs up to £6 weekly without receipts.
These exemptions apply provided the benefits meet the precise statutory conditions, ensuring no or Class 1A NICs liability arises, and they complement alternatives like payrolling for reportable items.

Compliance and Penalties

Common Compliance Issues

One common compliance issue in P11D involves misclassifying benefits (BiKs) as non-taxable expenses or allowances, which can lead to under-reporting and subsequent HMRC queries. For instance, reimbursements for setups exceeding the statutory £6 per week allowance for additional household expenses, or providing equipment for both business and private use without accounting for the private portion, must be treated as taxable BiKs rather than fully exempt allowances. To avoid this, employers should verify that any homeworking support aligns with HMRC's exemption criteria and report any excess via P11D or , ensuring clear documentation of actual costs incurred by employees. Another frequent error is under-valuing company cars on P11D forms by using outdated CO2 emissions data, which affects the taxable benefit calculation based on the car's and emissions . HMRC requires the CO2 figure from the vehicle's registration year, and failure to update this—such as applying current-year bands to older vehicles—results in incorrect cash equivalent values. Best practice includes cross-referencing the Society of Motor Manufacturers and Traders (SMMT) list or HMRC's approved data at the time of first registration to ensure accurate reporting in boxes 9 and 10 of the P11D. Late submissions of P11D and P11D(b) forms without a reasonable excuse also pose a significant , as the deadline is 6 July following the tax year end, with online filing mandatory since April 2023. Employers can mitigate this by implementing internal calendars tied to cycles and using HMRC's PAYE Online service for timely uploads, avoiding batching errors like submitting forms on separate days. Record-keeping failures, such as inadequate mileage logs for company cars or missing employee declarations on private use, often lead HMRC to assume 100% private use and apply the full taxable benefit. Regulations under the Employment Income Manual require employers to maintain contemporaneous records, including readings and fuel receipts, to substantiate restricted private mileage claims. To prevent this, adopt digital tracking tools compliant with HMRC standards and obtain signed employee confirmations annually, retaining them for at least three years post-submission. Oversights related to dispensations for expenses and benefits, which were abolished in April 2016 and replaced by statutory exemptions, continue to cause unnecessary P11D reporting if employers fail to transition properly to the new regime. Pre-2016 agreements required annual renewal applications via form P11DX, and non-renewal meant reverting to full reporting; today, employers must confirm items qualify under exemptions like qualifying travel or subsistence to avoid duplicative filings. Regular audits against HMRC's list of exempt items ensure compliance without over-reporting. In 2025, specific challenges arise from confusion over partial transitions to payrolling BiKs, where employers mix P11D reporting with payroll for different benefits, leading to inconsistent tax code adjustments. Additionally, software glitches in digital filing—such as validation errors in CO2 fields or duplicate submissions—have been reported during the voluntary payrolling phase ahead of the 2027 mandate. Employers can address these by selecting HMRC-recognised payroll software, testing submissions early, and attending HMRC webinars on hybrid reporting to clarify partial implementations.

Enforcement and Penalties

(HMRC) enforces with P11D requirements through a combination of routine reviews, targeted , and risk-based of employer submissions. These often involve examining end-of-year returns, including P11D and P11D(b) forms, to verify that all taxable expenses and benefits provided to employees and directors have been accurately reported. Enquiries may be initiated via random selection or based on identified risks, such as discrepancies in reported figures or patterns suggesting under-reporting. For most cases, HMRC must open an enquiry into a P11D return within 12 months of its filing date, though this period extends to four years for careless inaccuracies and up to six years (or 20 years for deliberate concealment) under discovery assessment rules where additional tax liabilities are identified. Penalties for non-compliance with P11D obligations are structured to address both late submissions and inaccuracies, with amounts scaled to the severity and impact of the breach. For late filing of the P11D(b) summary form, employers face an initial penalty of £100 for each 50 employees (or part thereof) for each month or part-month the return is overdue, alongside interest on any unpaid Class 1A contributions. For late filing of individual P11D forms, employers face an initial penalty of up to £300 per form under section 98 of the Taxes Management Act 1970, plus up to £60 per day for continuing failure. Inaccuracies may attract separate penalties under Schedule 24 of the Finance Act 2007. In cases of inaccuracies—whether careless or deliberate—penalties are calculated as a of the potential lost revenue (PLR), ranging from 0% to 30% for careless errors (reduced if unprompted disclosure is made), 20% to 70% for deliberate inaccuracies, and up to 100% for deliberate and concealed behavior; no penalty applies if reasonable care was taken to ensure accuracy. Additionally, failure to respond to HMRC enquiries can result in daily fines of £100 until compliance is achieved. Employers can mitigate penalties by demonstrating a reasonable excuse for non-compliance, such as unexpected failures, serious illness, or natural disasters that prevented timely filing, provided the return or payment is submitted as soon as the issue is resolved. Excuses like insufficient funds or oversight due to pressure of business are not accepted. Appeals against penalties must be lodged within 30 days of issuance, initially through an HMRC internal review, with the option to escalate to an independent tribunal if unresolved. Since 2020, HMRC has intensified digital enforcement for P11D compliance, leveraging automated data analytics and online submission portals to identify anomalies more efficiently. In 2025, enforcement efforts have emphasized preparation for mandatory payrolling of from April 2027, with targeted warnings and guidance issued to non-adopting employers to encourage transition and avoid future penalties.

References

  1. [1]
    How to complete P11D and P11D(b) - GOV.UK
    The return date for P11D and P11D(b) for 2024 to 2025 is 6 July 2025. For more information, read: the penalties section of the guidance on how to complete P11D ...PAYE draft forms · Guidance on how to complete... · Expenses and benefits
  2. [2]
    Expenses and benefits for employers: Deadlines - GOV.UK
    What you need to do, Deadline after the end of the tax year. Report expenses and benefits, 6 July. Give your employees a copy of the information, 6 July.
  3. [3]
    P45, P60 and P11D forms: workers' guide - GOV.UK
    Your employer might submit a P11D to tell HM Revenue and Customs ( HMRC ) if you get 'benefits in kind' (for example a company car or interest-free loan).
  4. [4]
    The future of P11D reporting - CIPP
    Jul 1, 2021 · The P11D return was introduced in the early 1960s, where the salary threshold was a mere £200. It is amusing to note that when introduced the ...Missing: 1976 | Show results with:1976
  5. [5]
    The payrolling of benefits: new employer obligations | Tax Adviser
    May 22, 2024 · The government announced in January 2024 its intention to make the payrolling of benefits compulsory from April 2026, thus doing away with P11Ds.
  6. [6]
    EIM21860 - Particular benefits: treatment of benefits that are trivial in ...
    May 22, 2014 · This is sometimes referred to as 'de minimis' grounds. There is no general statutory limit below which benefits are not taxable.Missing: threshold | Show results with:threshold
  7. [7]
    Expenses and benefits for directors and employees - a tax guide: 480
    ### Summary of P11D Information from EIM48000 Tax Guide
  8. [8]
    PAYE81740 - PAYE operation: international employments: tax ...
    Apr 13, 2016 · But employers must still complete form P11D and copy the information to the employee and submit completed forms P11D and P11D(b) to HMRC by 19 ...
  9. [9]
    Tax on trivial benefits - GOV.UK
    You'll need to report on form P11D whichever amount is higher: the salary given up; how much you paid for the trivial benefits. These rules don't apply to ...
  10. [10]
  11. [11]
    [PDF] Review of employee benefits and expenses: Interim report - GOV.UK
    HMRC processed around 4.5 million forms P11D from 300,000 PAYE schemes in 2010-11. Fewer than 20,000 forms P9D were filed. 3.3 In 2012, HMRC estimated the total ...
  12. [12]
  13. [13]
    [PDF] real time collection of tax on benefits in kind and expenses through ...
    Jun 18, 2014 · Employers are required by law to report the details of all BiKs after the end of the tax year on form P11D or P9D as appropriate. A separate ...
  14. [14]
    EIM20006 - The benefits code: types of income included - GOV.UK
    May 22, 2014 · Part 3 Chapters 2 to 11 ITEPA 2003 and Section 63(1) ITEPA 2003. Income within the benefits code is treated as earnings taxable as ...Missing: P11D | Show results with:P11D
  15. [15]
    [PDF] Overview of Tax Legislation and Rates - GOV.UK
    Mar 16, 2016 · (form P11D) under Part 4 of Chapter 2, Regulation 85 of the PAYE ... 1 January 1976, provided that such vehicles are not used commercially.
  16. [16]
    tax employees' benefits and expenses through your payroll - GOV.UK
    Using the online service for payrolling benefits and expenses means that you will not have to submit a form P11D. You must tell HMRC which benefits you want to ...
  17. [17]
    Check which expenses are taxable if your employee works from ...
    Mar 26, 2020 · Find out what equipment, services or supplies are taxable if your employees are working from home due to coronavirus (COVID-19).
  18. [18]
    Reporting and paying Income Tax and Class 1A National Insurance ...
    Apr 28, 2025 · This technical note confirms that mandatory payrolling will be introduced from April 2027 rather than April 2026, after feedback from external ...
  19. [19]
    Section 62 - Income Tax (Earnings and Pensions) Act 2003
    (b)any gratuity or other profit or incidental benefit of any kind obtained by the employee if it is money or money's worth, or. (c)anything else that ...
  20. [20]
    benefits in kind treated as earnings under Section 62 ITEPA 2003 ...
    May 22, 2014 · A benefit counts as earnings under Section 62 ITEPA 2003 if it is money's worth. Money's worth includes things that are capable of being converted into money.
  21. [21]
    Expenses and benefits: school fees for an employee's child - GOV.UK
    You must: report the cost on form P11D. deduct and pay Class 1 National Insurance (but not PAYE tax) on the cost of the fees through payroll.Missing: reportable | Show results with:reportable
  22. [22]
    Expenses and benefits: mobile phones: Overview - GOV.UK
    If your business pays the cost of an employee's mobile phone - what you must report to HMRC and what taxes and National Insurance are due.What to report and pay · What's exempt · Work out the value · Technical guidance
  23. [23]
    Expenses and benefits for employers: Reporting and paying - GOV.UK
    If you do not pay expenses and benefits through payroll. You must fill in an online form called a P11D and submit it to HMRC at the end of the tax year.
  24. [24]
  25. [25]
  26. [26]
    Expenses and benefits: relocation costs: What to report and pay
    You do not have to report or deduct anything for qualifying costs up to £8,000. Qualifying costs over £8,000. You must: report on form P11D; pay Class 1A ...
  27. [27]
    Expenses and benefits: clothing: What to report and pay - GOV.UK
    If you buy other clothing for employees, or lend it to them, you must: report the cost on form P11D. pay Class 1A National Insurance on the value of the ...
  28. [28]
    Travel — mileage and fuel rates and allowances - GOV.UK
    Apr 6, 2025 · Approved mileage rates from tax year 2011 to 2012 to present date ; Cars and vans, 45p, 25p ; Motor cycles, 24p, 24p ; Bicycles, 20p, 20p ...
  29. [29]
    Expenses and benefits for employers: Exemptions and dispensations
    If you're an employer and provide expenses or benefits to employees or directors, you might need to tell HMRC and pay tax and National Insurance on them.
  30. [30]
  31. [31]
    The benefits code: cash equivalent of benefits: the general rule
    May 22, 2014 · Section 203(2) ITEPA 2003 covers the general rule for finding the cash equivalent of a benefit. The cash equivalent is: the expense incurred by ...
  32. [32]
    benefits in kind: valuation - cash equivalent or annual values
    Mar 27, 2015 · The legislation setting out how to measure the cash equivalent of a benefit in kind is in Part 3 of the Income Tax (Earnings and Pensions) Act ...
  33. [33]
    Work out the appropriate percentage for company car benefits (480
    Use the CO2 emissions ready reckoners to work out the percentage benefit for petrol powered and hybrid powered company cars.
  34. [34]
    Benefit-in-kind (BIK) company car tax bands 2022 - 2028 - Fleet News
    The tables show future benefit-in-kind (BIK) tax bands (also known as company car tax) based on CO2 emissions of your vehicle.
  35. [35]
    Company Car Fuel Benefit Charge 2025/26 - Capture Expense
    Feb 28, 2025 · We will give you everything you need to know from what the car fuel benefit is, to the 2025/26 rates and how to report car fuel benefit to HMRC.
  36. [36]
    Rates and allowances: beneficial loan arrangements - GOV.UK
    Find out the actual and average official rates of interest on beneficial loan arrangements ... The actual official rates have been updated to include 2025.
  37. [37]
    Beneficial loan arrangements — HMRC official rates - GOV.UK
    Table of average official rates ; 2024 to 2025, 2.25 ; 2023 to 2024, 2.25 ; 2022 to 2023, 2.00 ; 2021 to 2022, 2.00.
  38. [38]
    Expenses and benefits: accommodation: Work out the value - GOV.UK
    Use HMRC's P11D working sheet if you need help working out the cash equivalent of accommodation benefits. Properties over £75,000. You must add an additional ...
  39. [39]
    The importance of calculating private use adjustments correctly - Azets
    Sep 2, 2025 · Following the 2024 trial, HMRC is now running a digital campaign to encourage businesses to make correct expense claims by accurately reporting ...
  40. [40]
    Calculate tax on employees' company cars - GOV.UK
    Work out taxable value. You can calculate taxable value using commercial payroll software. Or you can use HMRC 's company car and car fuel benefit calculator.Tax on company benefits · Car fuel and CO2 emissions data · P11D working sheet 2
  41. [41]
    Rates and allowances: National Insurance contributions - GOV.UK
    Apr 6, 2025 · The rate shown in the fourth column of the table (from 6 November 2022) is the Class 1A rate that applies to the whole tax year because Class 1 ...Rates and thresholds for · Rates and allowances · National Insurance contributions
  42. [42]
  43. [43]
    PAYE and payroll for employers: Keeping records - GOV.UK
    Your records must show you've reported accurately, and you need to keep them for 3 years from the end of the tax year they relate to.
  44. [44]
    EIM30210 - HMRC internal manual - GOV.UK
    May 22, 2014 · Almost all expenses or benefits that might previously have been covered by a dispensation will from 6 April 2016 be within an exemption from tax and NICs.
  45. [45]
    Guidance on how to complete P11D forms (480: Chapter 25)
    Each form P11D should contain details of all non-exempt expenses payments and benefits given for the employee concerned.Missing: obligations | Show results with:obligations
  46. [46]
    P11D Explained: tips for completing your P11D - BDO
    The forms must be submitted to HMRC by 6 July every year. In addition, employers are also required to complete and return the P11D(b), which calculates employer ...<|control11|><|separator|>
  47. [47]
    Pay employers' Class 1A National Insurance: Overview - GOV.UK
    You need to pay contributions on work benefits by 22 July each year for the previous tax year. You'll need to pay by 19 July if paying by post. Termination ...Online or telephone banking · Approve a payment through... · Direct Debit
  48. [48]
    Paying tax on employment benefits | Low Incomes Tax Reform Group
    Sep 10, 2025 · If you receive taxable benefits, your employer gives you a form P11D by 6 July following the end of the tax year, for example, by 6 July 2026 ...<|control11|><|separator|>
  49. [49]
  50. [50]
    A company car took away my child benefit: How work perks can ...
    Jun 10, 2024 · We asked three tax experts to explain the rules further. Benefit in kind: Company cars are included in taxable income and can affect your child.
  51. [51]
    What is Child Benefit? - Crunch Accounting
    You need to be careful that benefits in kind declared on your annual P11D return may affect your adjusted net income, and unexpectedly push you over the £50,000 ...
  52. [52]
    Payrolling benefits in kind - BDO
    Sep 25, 2025 · All employers will be required to payroll benefits in kind from April 2027. The start date was previously April 2026 but has been deferred by 12 months.
  53. [53]
    2025: Class 1A National Insurance contributions on benefits in kind ...
    Jul 2, 2025 · The old employer must complete form P11D(b) for the Class 1A National Insurance contributions payable in respect of the period up until the ...
  54. [54]
    VIT43700 - Specific issues: employee rewards and perks - GOV.UK
    Apr 13, 2016 · Employee perks are input tax if for business purposes. Output tax may apply to perks for specific individuals, like a car dealer giving ...Missing: P11D | Show results with:P11D
  55. [55]
    [ODF] Understanding tax administration for businesses - GOV.UK
    Businesses spent an average of 5 hours on reporting Expenses and Benefits in Kind through a P11D submission (5% said they didn't know). Businesses also spent an ...
  56. [56]
    [PDF] Real time collection of tax on benefits in kind and expenses through ...
    Payrolling benefits in kind provides the opportunity to remove or reduce employers' obligations to send returns to HMRC. It can also make the system of taxing ...
  57. [57]
    Technical note: Mandating the reporting of benefits in kind ... - GOV.UK
    Apr 28, 2025 · For a temporary period, we will retain the P11D and P11D(b) for employment related loans and accommodation. Voluntary payrolling of these ...
  58. [58]
    PAYE Settlement Agreements: Overview - GOV.UK
    PAYE Settlement Agreements (PSA) allow employers to make an annual payment to HRMC for some types of expenses and benefits - apply, renew, deadlines.Deadlines and payment · What's included · How to get a PSA
  59. [59]
    Rates and thresholds for employers 2024 to 2025 - GOV.UK
    The National Insurance Class 1A rate on termination awards and sporting testimonial payments for 2024 to 2025 is 13.8%. Pay employers' Class 1A National ...
  60. [60]
    PAYE Settlement Agreements: What's included - GOV.UK
    PAYE Settlement Agreements (PSA) allow employers to make an annual payment to HRMC for some types of expenses and benefits - apply, renew, deadlines.How to get a PSA · Tax on trivial benefits · Incidental overnight expenses
  61. [61]
    PSA1160 - Overview of PAYE Settlement Agreements - GOV.UK
    Apr 12, 2016 · The PSA calculator on SEES will calculate the tax and Class 1B NICs due under a PSA for you from 2008-09 onwards. You can then print off the calculation and ...Missing: NIC | Show results with:NIC
  62. [62]
    Table of benefits exempt from income tax and Class 1A NICs
    Apr 11, 2016 · Car, motor cycle and bicycle parking facilities at or near the place of work ... Eye tests and corrective appliances, Section 320A ITEPA 2003 ...Missing: phones | Show results with:phones
  63. [63]
    Expenses and benefits: homeworking: What to report and pay
    You can also continue to report expenses and benefits through a P11D form. Previous : Homeworking expenses and benefits that are exempt from tax · Next : Work ...
  64. [64]
    Common P11D errors and omissions - ACCA Global
    Common P11D errors and omissions . · form P11D for each employee in receipt of benefits in kind which have not been processed via the payroll; and · form P11D(b), ...
  65. [65]
    August 2025 issue of the Employer Bulletin - GOV.UK
    Aug 20, 2025 · You only need to tell HMRC that you do not need to make a return if we sent you an electronic notice to file a P11D(b) or a reminder to file a ...Missing: mandatory | Show results with:mandatory
  66. [66]
    Mandatory Payrolling of Benefits in Kind Guidance | CIPP
    Apr 29, 2025 · The delay in making the payrolling of most benefits in kind (BiKs) and expenses mandatory, so that this will now take effect from 6 April 2027 as opposed to 6 ...
  67. [67]
    EM8250 - Companies: Employer Compliance - HMRC internal manual
    Apr 12, 2016 · Enquiry Manual. From: HM Revenue & Customs; Published: 12 ... The End of Year returns on forms P35, P14, P11D and P11D(b) should be examined.
  68. [68]
    About compliance checks — CC/FS1a - GOV.UK
    Apr 30, 2025 · A compliance check allows us to check your tax position to make sure you're: We carry out some types of checks over the phone.
  69. [69]
    Compliance check series — CC/FS7A - GOV.UK
    Apr 30, 2025 · If you took reasonable care to get things right but your return or document still contained an inaccuracy, we will not charge you a penalty. ...
  70. [70]
    Disagree with a tax decision or penalty - GOV.UK
    You usually have 30 days from the date your penalty was issued to contact HMRC or make an appeal. If you miss the deadline, you'll need to give a reason.
  71. [71]
    Disagree with a tax decision or penalty: Reasonable excuses
    What to do when you disagree with a tax decision (HMRC1) - appealing against a decision, getting a review by HMRC and reasonable excuses.Missing: P11D | Show results with:P11D