How to Complete and Submit the HMRC P11D Form: P11D(b) and Class 1A

To complete and submit the HMRC P11D form, prepare one P11D for every employee or director who received taxable benefits or expenses that were not taxed through payroll, value each benefit under HMRC’s rules for that category, and file the P11Ds together with a P11D(b) online through PAYE Online or recognised payroll software by 6 July after the 5 April tax year end. Give each employee a copy by the same date, then pay the Class 1A National Insurance shown on the P11D(b) by 22 July if paying electronically, or 19 July by cheque.¹

Who Needs a P11D

You need a separate P11D for each employee or director who received a taxable benefit or expense that was not put through payroll during the tax year.² Common triggers are company cars, private medical cover, beneficial loans, employer-provided accommodation, and personal expenses paid on the employee’s behalf.

Two arrangements remove items from the P11D. If you registered to payroll benefits before the tax year began, tax is collected in real time through PAYE and those items are not reported on a P11D.³ A PAYE Settlement Agreement covers minor, irregular, or impracticable benefits with a single annual payment and takes those items off the P11D as well.⁴

Trivial benefits are also outside the P11D. A benefit qualifies if it costs no more than £50 including VAT and delivery, is not cash or a cash voucher, is not a contractual entitlement (including any salary sacrifice arrangement), and is not given in recognition of work performed. For directors and office holders of close companies, the total value of qualifying trivial benefits is capped at £300 per tax year.⁵ Qualifying relocation costs up to £8,000 are also exempt and do not appear on the form; only amounts above that go in Section J.⁶

What Goes in Each Section of the Form

Each P11D needs the employee’s full name, date of birth, and National Insurance number so HMRC can match the entry to the right tax record.⁷ The benefit itself belongs in one of the lettered sections:

Section A – Assets transferred, such as cars, property, or goods
Section B – Payments made on behalf of the employee
Section C – Vouchers and credit cards
Section D – Living accommodation
Section E – Mileage allowance and passenger payments
Section F – Cars and car fuel
Section G – Vans and van fuel
Section H – Interest-free and low-interest loans
Section I – Private medical treatment or insurance
Section J – Qualifying relocation expenses above £8,000
Section K – Services supplied
Section L – Assets placed at the employee’s disposal
Section M – Other items, including subscriptions and professional fees
Section N – Expense payments made to or on behalf of the employee

Valuing the Common Benefits

The taxable value for each benefit follows a specific HMRC rule. Getting the figure wrong is one of the fastest ways to attract a penalty. HMRC publishes working sheets WS1 through WS8 to walk you through the calculations. They are helpful but not compulsory.⁸

Company Cars

Multiply the car’s list price by the HMRC percentage set for its CO2 band and fuel type. Reduce the figure proportionally for any period the car was unavailable, and subtract any amount the employee paid toward its cost.⁹

Beneficial Loans

Where you lend an employee money below HMRC’s official rate of interest, the difference is a taxable benefit. The official rate for 2025–26 is 3.75%.¹⁰ The default averaging method adds the loan balance at the start of the tax year to the balance at the end, divides by two, and multiplies by the official rate. Subtract any interest the employee actually paid. Either HMRC or the employee may ask for the precise method, which tracks daily balances.¹¹

Living Accommodation

Start with the higher of the property’s annual value or the rent you pay as employer. If the property cost more than £75,000, add a further charge: take the cost minus £75,000 and multiply by the official rate of interest. Subtract any rent the employee paid.¹²

Private Medical Insurance

Report what you paid the insurer for the employee’s cover. Include the full premium where family members are covered on the same policy, and deduct any employee contributions.

The P11D(b) and Employee Copies

Alongside the individual P11Ds, submit a P11D(b). It totals the benefits reported across every P11D and declares the Class 1A National Insurance the organisation owes.² You still need a P11D(b) even if you payroll all benefits, because it confirms the Class 1A liability.⁷ From 6 April 2025 the Class 1A rate is 15% of the total taxable benefit value, up from 13.8%.¹³

You must also give each affected employee a copy of their P11D information by 6 July. This is a legal obligation, not a courtesy; employees need it to check their tax code and, where relevant, to complete self-assessment.¹

Submitting Online

File both the P11D and the P11D(b) through HMRC’s PAYE Online service or through recognised commercial payroll software. Paper submissions are not accepted for these forms. Keep the confirmation the system generates on successful transmission as proof of timely filing.

Paying Class 1A National Insurance

The Class 1A payment must reach HMRC by 22 July if paid electronically or 19 July if paid by cheque. Accepted electronic methods include online banking through Faster Payments, CHAPS or Bacs, Direct Debit, and debit or corporate credit card.¹⁴

Use a 17-character reference: your 13-character Accounts Office reference number (on the letter HMRC sent when you first registered as an employer), followed by the relevant tax year and the digits “13.” Leave those extra characters off and HMRC will allocate the payment to the current tax year, which creates a false underpayment against the year you meant to pay.¹⁵

A new Direct Debit can take up to five working days to set up, so arrange it well before the due date. If the deadline falls on a weekend or bank holiday, the payment must arrive on the last working day before.¹⁴

Penalties for Late or Wrong Filings

Late P11D(b) filing costs £100 per 50 employees for each month or part-month it remains outstanding.¹ An employer with 200 staff therefore faces £400 every month the return is overdue.

Inaccurate information carries a separate penalty based on the tax lost. A careless error, meaning you did not take reasonable care, can reach 30% of the lost revenue. A deliberate error can reach 70%, and deliberately concealing an inaccuracy can reach 100%. A genuine mistake made while taking reasonable care carries no penalty. Keep the records supporting each P11D entry for at least three years after the end of the tax year they relate to.¹⁶

Fixing a Mistake After You File

If you spot an error on a P11D you have already submitted, file an amended P11D through the GOV.UK online service. Amend the P11D(b) too if the correction changes the Class 1A National Insurance owed. If you missed filing a P11D that should have been submitted, send it as soon as possible and amend the P11D(b) at the same time. HMRC recommends including the reference “GfC13” in correspondence about corrections.¹⁷

What Changes in April 2027

HMRC plans to make payrolling of most benefits in kind compulsory from April 2027, originally scheduled for April 2026 and pushed back by a year. Once mandatory payrolling starts, employers will report income tax and Class 1A National Insurance through Real Time Information instead of filing P11Ds at year end.¹⁸

Employment-related loans and living accommodation will continue to be reported on P11D and P11D(b) on a temporary basis. Voluntary payrolling for those two categories opens from April 2027, with a mandatory date to follow. HMRC is also considering keeping the P11D process for globally mobile employees on modified PAYE arrangements. If you already payroll benefits voluntarily, you can register through the HMRC online service before the start of the tax year.³

1
GOV.UK. Expenses and Benefits for Employers – Deadlines
2
GOV.UK. How to Complete P11D and P11D(b)
3
GOV.UK. Tax Employees’ Benefits and Expenses Through Your Payroll
4
GOV.UK. PAYE Settlement Agreements – Tell HMRC What You Owe
5
Legislation.gov.uk. Income Tax (Earnings and Pensions) Act 2003 – Section 323A
6
GOV.UK. Expenses and Benefits – Relocation Costs – What You Do Not Need to Report
7
GOV.UK. Expenses and Benefits for Employers – Reporting and Paying
8
GOV.UK. PAYE – Car and Car Fuel Benefit (P11D WS2 and WS2b)
9
GOV.UK. Calculate Tax on Employees’ Company Cars
10
Legislation.gov.uk. The Taxes (Interest Rate) (Amendment) Regulations 2025
11
GOV.UK. Beneficial Loan Arrangements (480 – Chapter 17)
12
GOV.UK. Expenses and Benefits – Accommodation – Work Out the Value
13
GOV.UK. National Insurance Rates and Categories
14
GOV.UK. Pay Employers’ Class 1A National Insurance
15
GOV.UK. Pay Employers’ Class 1A National Insurance – By Debit or Corporate Credit Card
16
GOV.UK. Expenses and Benefits for Employers – Record Keeping
17
HM Revenue & Customs. Further Information, Feedback and Correcting Tax Returns
18
GOV.UK. Technical Note – Mandating the Reporting of Benefits in Kind and Expenses Through Payroll Software – An Update