A practical guide for small business owners and company directors • May 2026
If you provide any kind of perk to your employees or directors such as a company car, private medical cover, an interest-free loan, even a Christmas hamper above the trivial benefits limit then HMRC will probably want to know about it. That is where the P11D comes in. With the next filing deadline landing on 6 July 2026 and a major change to the system coming in 2027, now is a good moment to get on top of it.
What is a P11D?
A P11D is the form employers use to report taxable benefits in kind, often shortened to BIKs. These are non-cash perks that an employee receives because of their job, such as a company car, fuel for private use, private medical insurance, gym membership, or an interest-free or low interest loan above £10,000 provided to an employee or director.
There is also a P11D(b), which summarises the total Class 1A National Insurance the employer owes on those benefits.
In short, a P11D tells HMRC what was provided. A P11D(b) tells HMRC what is owed.
Who needs to file one?
Any employer who has provided taxable benefits or non-exempt expenses to employees or directors during the tax year ending 5 April 2026 will need to file. That includes:
- Limited companies with directors who receive any perks, including sole-director companies
- Employers who provide company cars, vans or fuel
- Businesses that pay for private medical insurance, gym memberships or interest-free or low interest loans over £10,000
- Employers offering relocation costs above £8,000 or staff entertainment above the trivial benefits limit
If you payrolled all of your benefits during the year, you may not need to file individual P11Ds — but you will still need to submit a P11D(b) and pay the Class 1A NIC.
Key deadlines for 2026
- 6 July 2026 — file your P11D and P11D(b) forms through HMRC's PAYE Online or your payroll software (paper forms are no longer accepted)
- 6 July 2026 — give each employee a copy of their P11D
- 19 July 2026 — Class 1A National Insurance payment due if paying by post
- 22 July 2026 — Class 1A National Insurance payment due if paying electronically
Late filing penalties start at £100 per 50 employees for each month (or part-month) the return is overdue, so a missed deadline can become expensive quickly.
The big change coming in April 2027
This is the part most business owners have not heard about yet, and it is a significant one.
From 6 April 2027, most benefits in kind will need to be reported through payroll in real time, rather than once a year on a P11D. The original date for this change was April 2026, but HMRC pushed it back by a year in April 2025 to give employers more time to prepare.
Under the new system, the value of each benefit will be added to the employee's payroll each pay period and reported to HMRC through your Full Payment Submission, the same way income tax and Class 1 NIC are reported today. A few benefits, most notably employer-provided accommodation and beneficial loans, will still be reportable on a P11D for now.
That means the 2025/26 P11D you file in July 2026 is, for most employers, the last full year of traditional P11D reporting.
What you should be doing now
- Gather the information early — company car details, BIK values, medical insurance premiums, loans and any reimbursed expenses outside HMRC's exemptions
- Check your payroll software is on the approved list and can handle the 2027 changes
- Consider voluntarily payrolling benefits in 2026/27 to get used to the process before it becomes compulsory
- Review the perks you offer — sometimes a small tweak can reduce tax for both employer and employee
- Talk to your accountant before, not after, the deadline
How we can help
P11Ds are one of those jobs that look straightforward until you look closely. Get the value of a benefit wrong, miss a reimbursed expense or forget a director's loan, and HMRC will notice.
At GMP Accountants, we handle P11D and P11D(b) preparation for businesses across a range of sectors. We will work out what needs reporting, calculate the Class 1A NIC, file everything on time and explain what is changing in 2027 so you can plan ahead with confidence.
If you would like a hand with this year's P11Ds, or want to talk through what mandatory payrolling will mean for your business, get in touch. A short conversation now can save a lot of stress in July.
This article is intended as general guidance and does not constitute tax advice. Please speak to us about your specific circumstances.