A P11D is used by employers to report taxable expenses and benefits in kind provided to employees or directors, such as company cars, private medical insurance, beneficial loans, living accommodation, or non-exempt reimbursed expenses.
For the 2025/26 tax year, P11D and P11D(b) forms must be submitted by 6 July 2026. Employees must also receive a copy of their P11D information by 6 July 2026. Class 1A National Insurance must be paid by 22 July 2026, or 19 July 2026 if paying by cheque.
1. Who Needs to File? #
Your SME may need to file P11Ds if you provided taxable benefits or expenses to:
- Employees
- Directors
- Family members of employees or directors, where the benefit arises from employment
You usually need to submit:
| Form | Purpose |
|---|---|
| P11D | Reports benefits and expenses for each relevant employee or director |
| P11D(b) | Declares the total Class 1A National Insurance due by the employer |
P11D and P11D(b) submissions must usually be made through PAYE Online for employers or commercial payroll software.
2. Common Benefits SMEs Should Check #
| Benefit or Expense | P11D Risk Area |
|---|---|
| Company cars and fuel | Often reportable; calculate using approved HMRC rules |
| Private medical insurance | Usually taxable |
| Beneficial loans | Reportable if above the relevant exemption threshold |
| Living accommodation | Often complex; seek advice if unsure |
| Company vans and fuel | May be taxable depending on private use |
| Gym memberships | Usually taxable unless specifically exempt |
| Reimbursed personal expenses | Usually reportable unless covered by an exemption |
| Assets transferred to employees | Often reportable |
| Staff entertaining or gifts | May be exempt, taxable, or covered by a PSA depending on facts |
3. Items That May Not Need Reporting #
Some expenses and benefits do not need to go on a P11D if they qualify for an exemption. Common examples include:
- Business travel and subsistence that meets HMRC rules
- Reimbursed business expenses with proper receipts
- Mobile phones, where the exemption conditions are met
- Trivial benefits, if all statutory conditions are met
- Annual staff events, if within the exemption limit and conditions
The key point is that the exemption must actually apply. Keep records showing why no P11D entry was needed.
4. Deadlines Checklist #
| Task | Deadline |
|---|---|
| Submit P11Ds to HMRC | 6 July 2026 |
| Submit P11D(b) to HMRC | 6 July 2026 |
| Give employees their P11D information | 6 July 2026 |
| Pay Class 1A NIC electronically | 22 July 2026 |
| Pay Class 1A NIC by cheque | 19 July 2026 |
| PSA tax and Class 1B NIC, if applicable | 22 October 2026 |
| PSA tax and Class 1B NIC by cheque, if applicable | 19 October 2026 |
5. SME Year-End Process #
A simple process for SMEs:
- List all benefits and reimbursed expenses provided from 6 April 2025 to 5 April 2026.
- Separate exempt items from taxable items.
- Check whether benefits were payrolled during the year.
- Calculate taxable values using HMRC rules.
- Prepare one P11D per employee/director who received reportable benefits.
- Prepare P11D(b) showing total Class 1A NIC due.
- File online by 6 July 2026.
- Give employees their P11D information by 6 July 2026.
- Pay Class 1A NIC by 22 July 2026 if paying electronically.
6. Payrolling Benefits and Future Changes #
Some employers already payroll benefits, meaning the employee pays tax through payroll during the year rather than via a later tax-code adjustment.
From April 2027, most benefits in kind and expenses are expected to be reported through the Full Payment Submission, the same RTI process used for payroll.
For SMEs, this means 2025/26 and 2026/27 are important transition years. Payroll software, HR records, benefit renewals, car data, medical insurance reports, and director loan tracking should be reviewed before mandatory real-time reporting begins.
7. Common Mistakes to Avoid #
- Missing directors who received benefits
- Assuming reimbursed expenses are automatically exempt
- Forgetting benefits provided to family members
- Not reconciling private medical insurance schedules to payroll records
- Using incorrect company car details, such as CO₂ emissions or availability dates
- Filing P11Ds but forgetting the P11D(b)
- Paying Class 1A NIC late
- Failing to give employees their P11D information by 6 July
8. Practical SME Controls #
Keep a simple benefits register with:
| Field | Example |
|---|---|
| Employee/director name | Jane Smith |
| Benefit type | Private medical insurance |
| Provider | Bupa / AXA / Vitality etc. |
| Start and end date | 6 Apr 2025 – 5 Apr 2026 |
| Gross cost or taxable value | £850 |
| Payrolled? | Yes / No |
| P11D required? | Yes / No |
| Evidence retained | Invoice, policy schedule, mileage log |
Bottom Line #
For the 2025/26 tax year, SMEs should file P11Ds and P11D(b) online by 6 July 2026, give employees their P11D information by the same date, and pay Class 1A NIC by 22 July 2026 if paying electronically.
Start preparing early, because benefit reporting is moving toward mandatory real-time payrolling. For more detail on how Class 1A National Insurance fits into your year-end obligations, or how temporary workplace rules affect what needs to be reported, see our related guides.
Frequently Asked Questions: P11D Reporting for UK SMEs #
What is a P11D form used for? #
A P11D is used by UK employers to report expenses and benefits in kind provided to employees and directors during the tax year that have not been taxed through PAYE. HMRC uses the information to ensure employees pay the correct amount of Income Tax on those benefits. Employers must submit a P11D for each affected individual and a P11D(b) declaring their Class 1A National Insurance liability.
When is the P11D deadline? #
P11D forms and the P11D(b) must be submitted to HMRC by 6 July following the end of the tax year. Employees must also receive copies of their P11D by the same date. Class 1A National Insurance contributions must be paid by 19 July (by post) or 22 July (electronically).
What benefits need to be reported on a P11D? #
Benefits that must be reported include company cars available for private use, private fuel, private medical insurance, low or interest-free loans over £10,000, living accommodation, non-cash vouchers, and employer-funded gym memberships. Allowable staff expense reimbursements, trivial benefits under £50, and benefits covered by a PAYE Settlement Agreement do not need to be reported.
What is the Class 1A National Insurance rate on P11D benefits? #
Employers pay Class 1A National Insurance at 13.8% of the taxable value of most benefits reported on P11D forms. This is an employer-only charge — employees pay Income Tax on the benefit value through their tax code but are not liable for Class 1A NICs. The total liability is declared on the P11D(b).
Can I payroll benefits instead of submitting P11D forms? #
Yes. Employers can register with HMRC to payroll benefits in kind, which means the taxable value is added to employees’ pay and taxed through PAYE each month. This removes the need for P11D forms for payrolled benefits at year-end. Payrolling will become mandatory for most benefits in the near future. Registration must be completed before the start of the tax year.
What happens if I submit a P11D late? #
HMRC charges automatic penalties for late P11D submissions — currently £100 per 50 employees for each month or part-month the forms are late. Interest also accrues on late Class 1A NIC payments. Persistent non-compliance can trigger a formal HMRC compliance check covering multiple tax years.
Do I need to submit a P11D if I provided no benefits? #
If you have not provided any taxable benefits or non-allowable expenses during the tax year, you do not need to submit individual P11D forms. However, if HMRC has previously asked you to submit a P11D(b), you may still need to file a nil return or confirm in writing that no benefits were provided. Check with HMRC’s employer helpline if you are unsure of your position.
Make P11D Season Less Stressful with Essential Expenses #
Year-end P11D reporting is one of the most time-consuming and risk-laden tasks on any SME payroll team’s calendar. Between identifying reportable benefits, applying the correct valuations, meeting submission deadlines, and paying Class 1A NICs on time — the margin for error is narrow and the consequences of getting it wrong are significant.
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