P11D Deadline 2026: What employers need to do now

If you provided any taxable benefits to employees or directors during the 2025/26 tax year, such as company cars, private medical insurance, beneficial loans, gym memberships, or living accommodation, the P11D deadline should be in your sights.

For the 2025/26 tax year, employers must:

• File P11D and P11D(b) forms by 6 July 2026 – Remember that paper forms are no longer accepted and submissions must go via HMRC’s PAYE Online service or recognised payroll software.
• Pay any Class 1A National Insurance by 22 July 2026 – If you are paying electronically or 19 July by post. For 2025/26, Class 1A NIC is charged at 15% on the value of reportable benefits.
• Give each affected employee a copy of their P11D information – This must be given to them by the 6 July deadline so they can complete their own tax affairs, if required.

Miss the filing deadline and HMRC’s automatic penalties bite quickly, with a fine of £100 per 50 employees for every month (or part month) the P11D(b) is late, plus interest and percentage-based penalties on unpaid Class 1A NIC.

These add up fast, even for small workforces.

A big change on the horizon: Payrolling becomes mandatory from April 2027

HMRC originally planned to make payrolling of benefits in kind (BIK) compulsory from April 2026, but the deadline was pushed back.

This means that from 6 April 2027, most benefits must be processed through payroll in real time, using compatible software, removing the need for individual P11Ds for BIK.

The 2025/26 tax year filed in July 2026 is, therefore, the last full year of traditional P11D reporting for most employers.

What you need to do

Here are some steps to help you get ready for this change in the year ahead:

• Audit your benefits now – List every taxable benefit you provide so nothing is missed when you transition.
• Warn employees about the “double tax” overlap – Anyone moving to payrolled benefits in 2026/27 may have tax collected on last year’s benefits via their tax code and this year’s benefits via their pay packet. This can create a temporary squeeze on take-home pay.
• You don’t need to register for mandatory reporting in April 2027 yet – HMRC’s registration facility for 2027/28 is expected to open in November 2026.
• You don’t need to scrap your P11D process – The P11D(b) and Class 1A NIC payment will still be required for 2026/27, even if you payroll benefits voluntarily.

If you’d like help reviewing your benefits, registering for payrolling or simply getting your P11Ds over the line, please get in touch with our team.