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What Is a P11D and When Do I Need to Submit One?

If you provide any perks or expenses to employees or directors outside of their regular salary, you may need to submit a P11D form to HMRC. This article explains what a P11D is, which benefits trigger the requirement, when the deadlines fall, and what happens if you miss them. It is relevant to employers, limited company directors, and anyone running a business with staff.

What is a P11D?

A P11D is a form that employers submit to HMRC to report benefits in kind and certain expenses provided to employees and directors during the tax year. If someone receives something of value from their employer that is not put through payroll — a company car, private medical insurance, or a gym membership, for example — HMRC needs to know about it so the correct amount of tax can be collected.

The P11D is named after the section of HMRC’s Pay As You Earn (PAYE) administration where it sits. Each individual employee or director who receives a reportable benefit gets their own P11D. The employer submits copies to HMRC and gives the employee a copy so they can check their own tax position.

A P11D is not part of your regular payroll cycle. It is an annual return filed after the end of the tax year.

What is a P11D(b)?

The P11D(b) is a separate but related form. It is the employer’s declaration of the total Class 1A National Insurance contributions (NICs) owed on all the benefits reported across all P11D forms submitted. In 2025/26, Class 1A NICs are charged on the employer — not the employee — at the rate of 13.8% on the taxable value of most benefits in kind. Check the latest HMRC guidance to confirm the exact Class 1A rate applicable to your position.

Even if you have no individual P11Ds to file but you did have a P11D obligation in the previous year, you still need to submit a P11D(b) to confirm there is nothing to report.

Who needs to submit a P11D?

You need to submit a P11D if you are an employer and you have provided one or more employees or directors with any benefit in kind or expense payment that has not already been taxed through payroll.

This includes:

  • Limited companies that provide benefits to directors (even if the director is the only person in the business)
  • Sole traders and partnerships with employees who receive non-cash benefits
  • Any employer who reimburses private expenses without a dispensation or approved scale rate

If none of your employees or directors received any benefits in kind during the tax year, and you have no Class 1A NIC liability, you do not need to file. However, if HMRC has previously received P11Ds from you, it is good practice to confirm that there is nothing to report by submitting a nil P11D(b).

Which benefits and expenses go on a P11D?

The list of reportable benefits is broad. Common examples include:

  • Company cars and fuel — one of the most common P11D entries; the taxable value is based on the car’s list price and its CO2 emissions
  • Private medical or dental insurance — the cost the employer pays is the taxable value
  • Interest-free or low-interest loans — if you lend an employee more than £10,000 (check the current de minimis threshold with HMRC) at below the official rate of interest, the benefit is reportable
  • Living accommodation — where provided by the employer and not covered by an exemption
  • Gym membership — if it is a personal membership paid by the company
  • Subscriptions and club memberships — where these are for personal rather than business use
  • Vouchers and credit tokens — including gift cards not put through payroll
  • Company vans used for private journeys — a fixed benefit in kind applies; check the latest HMRC guidance for the current figure
  • Assets transferred to employees — such as a laptop or phone given permanently to an employee
  • Expenses reimbursed without a proper business purpose — for example, paying an employee’s personal phone bill

If you run a limited company and want to make sure your expenses and benefits are recorded correctly from the outset, good bookkeeping will make the P11D process significantly easier.

What does not go on a P11D?

Not every benefit or payment needs to be reported. Several exemptions exist under HMRC rules:

  • Trivial benefits — small gifts costing £50 or less, not cash, not a reward for work, and not contractual. Directors of close companies can receive up to £300 per tax year in trivial benefits without a P11D entry.
  • Mobile phones — one mobile phone provided for business use (where the contract is in the employer’s name) is exempt
  • Workplace nursery and childcare — subject to specific conditions
  • Pension contributions — employer contributions to a registered pension scheme are not a benefit in kind
  • Approved mileage payments — reimbursements at or below the HMRC Approved Mileage Allowance Payment (AMAP) rates do not need to go on a P11D
  • Salary sacrifice arrangements agreed before April 2017 — subject to transitional rules; most modern salary sacrifice schemes are now taxable
  • Benefits covered by a PAYE Settlement Agreement (PSA) — if you have a PSA with HMRC, those benefits are handled separately and do not appear on individual P11Ds

Benefits that have been payrolled — brought through the payroll in real time — also do not need to go on a P11D form. More on that below.

P11D deadlines for 2025/26

For the 2025/26 tax year (6 April 2025 to 5 April 2026), the key dates are:

  • 6 July 2026 — deadline to submit all P11D and P11D(b) forms to HMRC and to give employees their copies
  • 19 July 2026 — deadline to pay any Class 1A NICs owed if you are paying by cheque or postal payment
  • 22 July 2026 — deadline to pay Class 1A NICs if you are paying electronically

These are fixed statutory deadlines. There is no grace period. If you are unsure whether you have any benefits to report, review your company bank statements, credit card statements, and expense claims before the April year-end so you are not rushing in June.

Penalties for late or incorrect P11Ds

HMRC takes late or inaccurate P11Ds seriously. The main penalties to be aware of are:

  • Late P11D(b) — HMRC can charge a penalty of £100 per 50 employees for each month or part month the form is late
  • Late Class 1A NIC payment — interest accrues from the payment deadline and surcharges apply in the same way as other PAYE late payment penalties
  • Inaccurate returns — if HMRC discovers benefits have been omitted or undervalued, it can raise an assessment for unpaid tax and NIC, plus interest and a potential penalty based on the behaviour involved (careless, deliberate, or deliberate and concealed)

Errors on P11Ds also affect employees directly. The benefit value feeds into their personal tax account, which can affect their tax code and mean they owe tax through self assessment if they are registered, or through a PAYE code adjustment.

Payrolling benefits as an alternative

Since April 2016, HMRC has allowed employers to payroll most benefits in kind. This means instead of reporting them at the year-end on a P11D, you report the taxable value through your real-time payroll each month, and the employee pays the tax on it through their pay packet.

From April 2026, HMRC plans to make payrolling of benefits mandatory for most employers. If you are not already payrolling your benefits, now is the time to consider it. You need to register with HMRC before the start of the tax year in which you want to payroll — registration cannot be backdated.

Payrolling removes the need for individual P11D forms for the benefits you have registered. You still need to file a P11D(b) to declare and pay the Class 1A NICs, but the administrative burden is lower. If your current payroll software supports benefit payrolling, it is worth speaking to an accountant about the transition before April 2026.

P11Ds and limited company directors

Many small limited company directors assume that because they are both the employer and the employee, P11Ds do not apply to them. That is not correct. A director is an office holder and falls within PAYE. If the company pays for anything that benefits you personally — private medical insurance, your personal mobile contract, a company car used for private mileage — the company needs to report that on a P11D in your name.

This catches a surprising number of directors out. Common examples:

  • The company pays for a gym membership in the director’s name
  • The company pays a personal insurance policy on behalf of the director
  • The company has a car on its books that the director drives privately
  • The director borrows money from the company (a director’s loan) and the balance exceeds £10,000 — check the current de minimis with HMRC — at any point in the year

Directors who take dividends also need to think about how their overall income is taxed. In 2025/26, the dividend allowance is £500. Dividends above that are taxed at 8.75% (basic rate), 33.75% (higher rate), or 39.35% (additional rate) depending on total income. Benefits in kind reported on a P11D can push a director into a higher tax bracket, which is worth modelling in advance.

If you run a limited company, your corporation tax position and your personal tax position are connected. Benefits in kind affect both.

How to submit a P11D to HMRC

P11Ds must be submitted online. HMRC no longer accepts paper P11D forms for most employers. You can file through:

  • HMRC’s PAYE Online service — suitable for employers with fewer than 500 employees who file a small number of forms
  • Commercial payroll or accounts software — most payroll packages include P11D functionality; software such as Xero, BrightPay, and Sage can handle this. If you need help with your software, Xero training can help you use the platform correctly from the start
  • Your accountant or payroll bureau — they can file on your behalf using their own software or agent access

Once you have submitted, give each affected employee a copy of their P11D by 6 July. Employees need this to check their tax code and to complete any self assessment return where required.

Keep copies of all P11Ds and supporting records for at least six years. HMRC can open an enquiry into benefits in kind as part of a wider PAYE compliance check, and you will need the paperwork to defend your position.

Getting your P11D right

The P11D process is one of those areas where small mistakes can have a disproportionate impact. A missed benefit in kind or an incorrectly valued company car can result in an HMRC enquiry, back-tax for the employee, and a penalty for the employer. The good news is that with organised records and a clear understanding of what counts as a reportable benefit, the filing itself is straightforward.

If you are unsure whether something needs to go on a P11D, the safest approach is to ask an accountant before the year-end — not after. And if you have staff, it is worth reviewing whether payrolling your benefits before the April 2026 mandatory deadline makes sense for your business.

Frequently asked questions

Do I need to submit a P11D if I am the only director of my company?

Yes, if your company has provided you with any benefit in kind during the tax year — such as a company car, private medical insurance, or interest-free loan above the de minimis threshold — the company must file a P11D in your name as a director, even if you are the only person in the business.

What is the P11D deadline for the 2025/26 tax year?

The deadline to submit P11D and P11D(b) forms to HMRC and provide copies to employees is 6 July 2026. Class 1A NICs must be paid by 19 July 2026 (post) or 22 July 2026 (electronic payment).

Can I correct a P11D after I have submitted it?

Yes. If you discover an error after submission, you can amend a P11D by writing to HMRC or, in some cases, submitting an amended return through your payroll software. You should correct errors as quickly as possible to avoid interest and penalties building up on any underpaid Class 1A NICs.

Does a private medical insurance policy always go on a P11D?

If the employer pays for an individual employee’s or director’s private medical insurance, the cost is a benefit in kind and must be reported on a P11D. The taxable amount is the premium the employer pays. The exception is where the benefit has been payrolled — in that case it does not appear on a P11D form.

What is the difference between a P11D and a P60?

A P60 is the annual summary of pay and tax deducted through PAYE — it covers salary and wages. A P11D is separate and covers non-cash benefits and expenses provided outside of payroll. Employees may receive both documents after the end of the tax year.

Will I still need to file P11Ds after April 2026?

HMRC intends to make payrolling of benefits mandatory from April 2026, which will remove the need for most individual P11D forms. However, employers will still need to submit a P11D(b) to declare and pay Class 1A NICs. Check the latest HMRC guidance as the rules around this transition are still being confirmed.