Deadline approaching for completion and submission of P11D forms
As the 2025/26 tax year draws to a close, employers should ensure they are fully prepared for their upcoming P11D compliance obligations. P11D and P11D(b) forms must be filed by 6 July following the end of the tax year – meaning the deadline for the 2025/26 tax year is 6 July 2026.
Failure to meet this deadline can lead to significant penalties. Late P11D forms attract penalties of £100 for every 50 employees per month, and HMRC may continue charging until forms are submitted. In addition, Class 1A National Insurance Contributions (NICs) must be paid by 22 July 2026, with interest charged on any late payments.
When is a P11D required?
A P11D is required when taxable benefits or expenses are provided to employees outside of payroll, and the benefit is not being processed through a registered payrolling benefits system.
Common examples include:
- Company cars and fuel
- Private medical insurance
- Interest-free or low-interest employee loans
- Employer-provided living accommodation
- Assets made available to employees for personal use
- Non-business expenses, such as gym memberships or personal expenditure
The accompanying P11D(b) form confirms that all required P11Ds have been completed and declares the total Class 1A NIC liability due (including benefits reported via your payroll).
Could voluntary payrolling of benefits be worthwhile?
With mandatory payrolling of benefits taking effect from April 2027, employers may find it advantageous to adopt voluntary payrolling ahead of time for the 2026/27 tax year. Registration must take place before the start of the tax year, meaning before 6 April 2026.
Voluntary payrolling can offer several benefits:
1. Reduction in administrative burden
Removes the need for annual P11D submissions for most benefits.
2. Improved accuracy and employee experience
Tax is collected in real time, reducing the likelihood of PAYE coding issues, unexpected year‑end liabilities, or employee queries about benefit taxation.
3. Stronger compliance and risk management
Embedding processes early helps ensure systems, data quality, and internal controls are ready ahead of the mandatory reporting regime – reducing exposure to errors, penalties, and rework later on.
We’re here to help
Our specialist Employer Solutions team can assist with:
- Assessing which benefits should be payrolled
- Registering voluntarily for 2026/27 payrolling of benefits
- Preparing and submitting P11D and P11D(b) forms
- Ensuring your payroll systems and processes are robust, compliant, and ready for the mandatory transition in 2027
If you would like tailored advice on meeting your P11D obligations or exploring voluntary payrolling, please get in touch with our specialist Employment Tax team.
