A P11D reports, for one employee or director, the taxable expenses and benefits the employer provided in a tax year that were not taxed through payroll. The P11D(b) is the employer’s return of the total Class 1A National Insurance due on those benefits. Both must be filed online by 6 July after the end of the tax year, employees must have their copy by the same date, and the Class 1A must reach HMRC by 22 July (19 July by cheque).
Who needs a P11D?
HMRC’s guidance on completing the forms says a separate P11D is needed for each director or employee who received taxable expenses payments, benefits or facilities that are not covered by an exemption. Benefits given to the employee’s family or household count as given to the employee, and paragraph 25.3 of booklet 480 says items must be included whether the payment went to the employee or to a third party such as a credit card company.
No P11D is needed for an individual where:
- there are no taxable expenses or benefits to report;
- everything has been taxed through payroll (see below);
- the items are covered by a PAYE Settlement Agreement; or
- the items fall within an exemption, such as the paid and reimbursed expenses exemption or the trivial benefits exemption.
A broader overview of which perks are taxable is in benefits in kind and the P11D.
What goes on the P11D?
The form is divided into sections by type of benefit. HMRC’s completion guide covers, among others:
- assets transferred to the employee, at market value or cost;
- payments made on the employee’s behalf, and vouchers and credit cards;
- living accommodation;
- mileage allowance payments above the approved amounts;
- cars and car fuel, including list price, accessories, CO2 figure, fuel type key letter, capital contributions and payments for private use;
- vans and van fuel;
- beneficial loans, which can be disregarded if all loans outstanding total £10,000 or less throughout the year;
- private medical treatment or insurance;
- qualifying relocation costs above £8,000;
- services supplied, assets placed at the employee’s disposal, and other items such as subscriptions.
Figures go in gross. Paragraph 25.10 of booklet 480 says amounts must include the full VAT even if the employer recovers it, and paragraph 25.11 says entertaining costs are shown in full even though they are disallowed for the business. Where the employee has made good a benefit by 6 July, the amount goes in the “amount made good” box so that only the net figure is taxed.
What does the P11D(b) declare?
The P11D(b) lists the employees who need a P11D, gives the total benefits liable to Class 1A, any adjustments, the Class 1A due, and a declaration. Class 1A is charged at the employer Class 1 rate for the year, which CWG5 confirms is 15% for 2026 to 2027, on the same cash equivalents reported for tax. Section 4 of the form allows adjustments, for example where a P11D figure includes amounts already taxed through PAYE or relates to someone with no National Insurance liability.
The P11D(b) is needed even if the employer has payrolled every benefit. CWG5 explains that payrolling deals with income tax only, so the employer still reports and pays Class 1A separately.
What are the deadlines?
GOV.UK sets the following dates after the end of each tax year:
| Action | Deadline |
|---|---|
| File P11Ds for all relevant employees | 6 July |
| Give each employee a copy of their information | 6 July |
| File the P11D(b) | 6 July |
| Pay Class 1A National Insurance | 22 July (19 July if paying by cheque) |
| Pay tax and Class 1B under a PAYE Settlement Agreement | 22 October (19 October by cheque) |
For the current 2026 to 2027 tax year, that means filing by 6 July 2027 and paying Class 1A by 22 July 2027. CWG5 explains that a Class 1A payment needs the Accounts Office reference followed by the year and the suffix 13 (for example, 2713 for a payment made in July 2027 for 2026 to 2027); without it HMRC allocates the payment to the current year. Late filing and payment penalties are covered in penalties for late or wrong P11D forms.
How are the forms submitted?
Since 6 April 2023 employers must file P11D and P11D(b) online unless they are digitally exempt, and HMRC no longer accepts lists of P11D information (paragraphs 25.6 and 25.7 of booklet 480). Employers with fewer than 500 employees can use HMRC’s PAYE Online service; those with more must use payroll software. Booklet 480 says the P11D and P11D(b) must be submitted at the same time. Paper forms, with a covering letter, are accepted only from an employer that has stopped trading, and the forms can only be filed once the tax year has ended.
How does payrolling change this?
An employer that registered online before the start of the tax year to payroll all its benefits only needs to send the P11D(b). CWG5 warns that an employer who payrolled benefits without registering must still file P11Ds and mark which benefits were taxed through payroll. More detail is in payrolling of benefits in kind.
Payrolling is becoming compulsory in stages. HMRC’s published policy is that from April 2027 company cars, car fuel, vans, van fuel and employer provided medical benefits must be reported through payroll in real time, with most other benefits following from April 2028. Loans and accommodation are not part of that timetable for now. The P11D for 2026 to 2027, due by 6 July 2027, will therefore still include cars and medical cover for employers that do not payroll them.
How does this work in practice?
Illustration only. A company with a director and two staff does not payroll benefits. For 2026 to 2027 it provides the director with a company car with a cash equivalent of £6,000, gives each member of staff private medical insurance costing £900, and pays one of them a gym membership of £480.
- Three P11Ds are filed: £6,000 car benefit for the director, £900 medical plus £480 under other items for the first employee, and £900 medical for the second.
- Total benefits liable to Class 1A: £6,000 + £900 + £900 + £480 = £8,280.
- Class 1A at 15%: £1,242, shown on the P11D(b) and paid by 22 July 2027.
- Each employee receives a copy of their P11D figures by 6 July 2027.
What records and mistakes should employers watch for?
GOV.UK requires records of every expense and benefit, the information used to work out the figures, and any employee contributions, kept for 3 years from the end of the tax year. Errors that come up repeatedly include:
- leaving out benefits paid to a family member or settled by a third party;
- reporting net of VAT;
- filing P11Ds for payrolled benefits when registered, or failing to file them when payrolling without registering;
- forgetting the P11D(b) when all benefits are payrolled;
- missing the year suffix on the Class 1A payment reference; and
- not giving employees their copy, which they need to check their tax code or Self Assessment return.
The P11D cycle sits alongside the other payroll year end tasks.
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Related Accountapedia entries
- Which expenses and benefits attract Class 1 NI
- Employer paying an employee’s personal bills
- Employer NI on termination payments
- Company van benefit and van fuel benefit
- Gym membership and sports facilities for staff
- Living accommodation provided to employees
Sources
- GOV.UK: How to complete forms p11d and p11db
- GOV.UK: Guidance on completion of forms p11d 480 chapter 25
- GOV.UK: Employer reporting expenses benefits
- GOV.UK: 2026 class 1a national insurance contributions on benefits in kind ter
- GOV.UK: Changes to reporting of benefits in kind from april 2027
- GOV.UK: The phased introduction of mandatory payrolling for benefits in kind
Reviewed by Christine Anderson, Broker, Solar Protect. Last reviewed 19 October 2026. Part of Accountapedia, the Solar Protect guide to UK tax and accounting. This page is general information, not personalised advice.