Form P46(Car) tells HMRC that an employer has started or stopped making a car available for an employee’s private use. It is a quarterly return due 28 days after the end of the tax quarter in which the change happened, so the main deadlines are 2 August, 2 November, 2 February and 3 May. Employers who tax car benefit through payroll do not file it, because the car details go to HMRC on the Full Payment Submission instead.
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What is form P46(Car) for?
The legal requirement is regulation 90 of the Income Tax (Pay As You Earn) Regulations 2003, headed “Quarterly return if a car becomes available or unavailable”. It applies where the benefit of a car is taxed as earnings under section 120 or section 120A of the Income Tax (Earnings and Pensions) Act 2003, the second of these being the rule for cars provided through salary sacrifice. The return keeps HMRC’s records of the car up to date during the year, rather than leaving them until the P11D after the year end. The August 2026 and October 2026 employer bulletins repeat the point: for any car change an employee has within the tax year, a P46(Car) must be submitted.
P46(Car) does not replace the year end reporting. GOV.UK reminds employers that they must still report the car on form P11D and pay Class 1A National Insurance on the value of the car benefit, as explained in our guide to forms P11D and P11D(b).
Which changes must be reported?
Regulation 90(1) lists three events in a tax quarter:
- a car becomes available to the employee
- a car stops being available
- a car is available and the employee’s employment becomes subject to the benefits code
GOV.UK puts the same rules in everyday terms: send a P46(Car) if you provide a company car, stop providing one or provide someone with an additional car. Private use includes journeys between home and work unless the employee is travelling to a temporary place of work, so a car taken home each night is reportable even if it is used mainly for business.
Regulation 90(1A) switches the requirement off in two cases. The first is where a car becomes available or unavailable only because one car is replaced with another. GOV.UK still asks employers to tell HMRC about a replacement, using PAYE Online, payroll software or the year end forms. The second is where Chapter 3A of the regulations applies, which is the chapter for payrolling benefits.
No report is needed for genuine pool cars, cars adapted for an employee with a disability where the only private use is home to work travel, or emergency vehicles used only by on call employees of the police, fire and rescue, ambulance or paramedic services.
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What are the quarterly deadlines?
Regulation 90(2) requires the information not later than 28 days after the end of the tax quarter. Tax quarters end on 5 July, 5 October, 5 January and 5 April. GOV.UK sets out the dates as follows:
| Change takes place | Tell HMRC by |
|---|---|
| 6 April to 5 July | 2 August |
| 6 July to 5 October | 2 November |
| 6 October to 5 January | 2 February |
| 6 January to 5 April | 5 April for an electronic form, 3 May for a printed form |
The last row is the only one that differs between online and paper filing on GOV.UK, even though the regulation itself allows 28 days after 5 April. The practical answer is to file online as soon as the change is known.
What information goes on the form?
Regulation 90(3) requires the employee’s name and National Insurance number if known, details of the car, the provisional sum calculated under section 121A, any capital contribution by the employee towards the car or qualifying accessories, any amount the employee must pay as a condition of private use, and whether fuel is provided for private use. HMRC’s guidance adds the employer’s name, telephone number and PAYE reference.
Two car details cause most rejections. A diesel car meeting the Euro 6d standard, also called RDE2, is reported as fuel type F; DVLA’s vehicle enquiry service and the V5C show whether a car meets the standard. A car with CO2 emissions of 1g to 50g per km needs its zero emission mileage, the distance it can travel in electric mode without recharging, which the leasing company or the certificate of conformity will give.
The form can be filed through HMRC’s online service, through payroll software or by completing the form on screen and posting a printed copy to the address shown on it.
When does payrolling remove the need to file?
Where an employer has registered to tax benefits through payroll, Chapter 3A of the PAYE regulations applies and regulation 90 does not. HMRC’s guidance on sending car data explains that payrolling employers must send car details on the Full Payment Submission, mandatory since 6 April 2018 where a car or car fuel is payrolled. The fields cover make and model, date first registered, CO2 emissions, zero emission mileage, fuel type, a car identifier, the calculated price, the dates the car was available from and to, and the cash equivalent. HMRC’s guidance states that employers who do not payroll must continue to complete form P46(Car). Our guide to payrolling benefits in kind covers registration.
Payrolling is voluntary until April 2027. HMRC’s guidance says registration for the 2026 to 2027 tax year closed on 5 April 2026, so an employer that did not register in time must use P46(Car) for changes during 2026 to 2027. HMRC’s July 2026 policy paper confirms that from April 2027 most employers providing company cars, car fuel, vans and van fuel and employer provided medical benefits will have to report them through payroll in real time. The legislation is in draft for Finance Bill 2026 to 2027, so check the final rules before relying on it.
Illustration: working out the deadline
Illustration only. A company gives a new employee a car on 20 May 2026 and withdraws another employee’s car on 10 January 2027. Neither car is payrolled. The first change falls in the quarter 6 April to 5 July 2026, so the P46(Car) is due by 2 August 2026. The second falls in the quarter 6 January to 5 April 2027, so HMRC should receive it by 5 April 2027 online or 3 May 2027 on paper. If the second employee had simply swapped one car for another on 10 January, regulation 90 would not require a P46(Car), but GOV.UK still asks the employer to tell HMRC about the replacement.
What goes wrong in practice?
- Treating P46(Car) as optional because the P11D will be filed anyway. The quarterly return is a separate legal obligation under regulation 90, and car benefit also feeds into the employee’s tax code.
- Filing a P46(Car) for a payrolled car. If the car is in payroll, the details belong on the FPS.
- Missing a withdrawal. When an employee leaves or hands back a car, regulation 90 still requires a report that the car has become unavailable.
- Leaving out zero emission mileage for a plug in hybrid, or reporting an RDE2 diesel as an ordinary diesel, which affects the car benefit calculation.
- Forgetting that a salary sacrifice car is still reportable. Regulation 90 expressly covers cars taxed under section 120A.
The calculation behind the figures on the form is covered in our guide to company car benefit in kind.
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Related Accountapedia entries
- Notifying PSC changes: which form to use
- Reporting a gift into trust on form IHT100
- Car allowance or company car: the tax comparison
- Can a business reclaim VAT on a car
- Reducing company car benefit with contributions
Sources
- legislation.gov.uk: SI 2003/2682, regulation 90
- GOV.UK: Tell hmrc company car
- GOV.UK: Tell hmrc about a car provided to an employee for private use
- GOV.UK: Sending car data to hmrc payrolling car benefit
- GOV.UK: What to report and pay
- GOV.UK: October 2026 issue of the employer bulletin
- GOV.UK: August 2026 issue of the employer bulletin
- GOV.UK: Getting ready for mandatory payrolling of benefits in kind
- GOV.UK: Changes to reporting of benefits in kind from april 2027
Reviewed by Christine Anderson, Broker, Solar Protect. Last reviewed 24 October 2026. Part of Accountapedia, the Solar Protect guide to UK tax and accounting. This page is general information, not personalised advice.