The P11D Form & Benefits in Kind: A UK Employer’s Guide (2026/27)

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Table of Contents

P11D and P11D(b): what is the difference?
Which benefits in kind may need reporting?
How benefits are reported in 2026/27
- Benefits already payrolled
- Benefits not payrolled
2026/27 P11D deadlines
Mandatory payrolling from April 2027
Practical employer checklist
Official guidance

Employers providing taxable expenses or non-cash benefits to employees or directors must report them correctly to HMRC and pay any employer National Insurance due. For the 2026/27 tax year (6 April 2026 to 5 April 2027), the P11D and P11D(b) system still applies, but employers should also prepare for phased mandatory payrolling from April 2027.

This guide explains what a P11D is, which benefits are reportable, the 2026/27 deadlines and the latest HMRC payrolling changes.

P11D and P11D(b): what is the difference?

Form	What it reports	Who it covers
P11D	Taxable expenses and benefits that were not fully taxed through payroll.	One form for each affected employee or director.
P11D(b)	The employer’s declaration of total benefits and Class 1A National Insurance due, including relevant payrolled benefits.	One employer return.

A P11D is not normally needed for a benefit that has been fully payrolled correctly. A P11D(b) may still be required to report and pay Class 1A National Insurance.

Which benefits in kind may need reporting?

A benefit in kind is a non-cash benefit with monetary value provided because of employment. Common examples include:

company cars, vans and private fuel;
private medical or dental insurance;
beneficial or interest-free employment-related loans;
living accommodation;
gym memberships, vouchers and personal bills;
assets transferred to an employee or made available for private use.

The tax and National Insurance treatment depends on the benefit and how it was provided. Exempt benefits should not be reported. For example, a qualifying trivial benefit normally costs no more than £50, is not cash or a cash voucher, is not a reward for work and is not provided under salary sacrifice. A £300 annual cap applies to qualifying trivial benefits provided to directors of close companies and members of their households.

How benefits are reported in 2026/27

Benefits already payrolled

If an employer registered a benefit for voluntary payrolling before 6 April 2026, it can continue to tax that benefit through payroll during 2026/27. The taxable cash equivalent is included through payroll so that the employee pays tax during the year. Do not submit a duplicate P11D for a fully payrolled benefit, but include the relevant amount in the P11D(b) calculation.

The voluntary registration service closed on 5 April 2026. Employers cannot newly register or change their reporting method for the current 2026/27 tax year. Existing registrations can still be viewed and employees can be excluded where HMRC’s rules permit.

Benefits not payrolled

For taxable benefits not payrolled during 2026/27, submit an electronic P11D for each affected employee or director after 5 April 2027. HMRC normally collects the employee’s tax through an adjustment to their PAYE code. Submit the employer’s P11D(b) as well where Class 1A National Insurance is due.

HMRC generally accepts P11D and P11D(b) submissions through PAYE Online for employers with fewer than 500 employees, or through compatible payroll software. Paper forms are normally accepted only where the business has ceased trading.

2026/27 P11D deadlines

6 July 2027: submit P11D forms and the P11D(b) for benefits provided in 2026/27, and give employees a copy of their P11D information.
19 July 2027: pay Class 1A National Insurance if paying by a non-electronic method.
22 July 2027: pay Class 1A National Insurance electronically.

Keep records supporting how each benefit was valued and any employee contribution. Late or incorrect returns can lead to penalties and interest. The Class 1A rate for 2026/27 is generally 15%, although the precise NIC treatment should be checked for each benefit.

Mandatory payrolling from April 2027

HMRC has replaced the earlier one-date proposal with a phased introduction. From 6 April 2027, mandatory real-time reporting through Full Payment Submissions is planned for:

company cars and car fuel;
vans and van fuel; and
employer-provided medical benefits.

Mandatory payrolling is planned to extend to most remaining benefits from 6 April 2028. The timetable for employer-provided loans and accommodation will be confirmed separately. Secondary legislation and final operational details may still refine the scope, so employers should confirm payroll-software readiness and monitor HMRC updates before the 2027/28 tax year.

Practical employer checklist

Maintain a complete register of benefits and employee contributions.
Identify which benefits were validly registered for payrolling before 6 April 2026.
Calculate cash equivalents using the rule for each benefit.
Reconcile payroll, P11D and P11D(b) figures before submission.
Budget for Class 1A National Insurance and pay under the correct reference.
Ask your payroll provider how it will support April 2027 real-time benefit reporting.