P11Ds is another tax form in the business world that is reviewed by the HMRC to calculate whether additional or less income tax is owed for taxable benefits or reimbursed expenses of each member of a company. Like all things with HMRC, there is a deadline that is non-negotiable, and failure to do so breaches PAYE regulations, exposing you to compliance enforcement.
But what is the deadline? In this article, Real Business outlines this very question, as well as what counts as taxable benefits and expenses, the best practices for compliance and more.
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When is my P11D deadline?
Employers must submit two separate kinds of P11D forms per employee, and both have a deadline of July 6th. This date remains unchanged regardless of the tax year and will continue unless HMRC decides otherwise. All submissions must be made online, as paper submissions are no longer permitted.
What types of P11Ds exist?
There are four types, and all adhere to the same P11D deadline:
- 1/4 Form P11D – Employers fill these out to report expenses and benefits that are taxable by HMRC. Report benefits in kind by itemising them, marking each with the cash equivalent value. Taxable expenses (meaning expenses made purely for the business) must also be listed here, unless they are within HMRC’s exempt or approved categories. P11Ds are filled out by listing the employer and employee details in the header, laying out the taxable expenses and benefits across 14 sections, and putting down a footer/declaration.These 14 sections outline the articles covered:
- A – Assets transferred to the employee.
- B – Payments made on the employee’s behalf.
- C – Credit cards and vouchers.
- D – Living accommodation.
- E – Mileage allowance payments that are not taxed at source.
- F – Company cars and fuel.
- G – Company vans.
- H – Beneficial loans (over £10,000).
- I – Private medical treatment or insurance.
- J – Qualifying relocation expenses.
- K – Services supplied (e.g., employer‐provided gym).
- L – Assets placed at the employee’s disposal (e.g., laptops).
- M – Other items (subscriptions, professional fees).
- N – Expense payments made to or on behalf of the employee.
- 2/4 Form P11D (b) – This form declares the class 1a national insurance contributions (NICs) due on all benefits reported via P11D forms. The header, employee details, and contact details must all be filled out before being followed by the total cash equivalent value of all benefits and expenses, then multiplied by 15%.
- 3+4/4 P11D (and B) correction form – If you make a mistake during a submission, you are expected to use a correction form to amend it. There are two types of correction forms depending on whether you’re correcting a P11D or P11D (b).
What are the consequences of missing the P11D deadline?
There are several consequences for missing the deadline:
- Late filing penalties – Failing to file on time will incur a £100 penalty charge for every 50 employees who receive benefits in kind. This charge is applied against for every month until the form has been submitted.
- Late payment interest charges – Payment of Class 1a NICs is due by the 19th of July for cheques and the 22nd of July when paid electronically. However, when late, these payments incur interest charges at an 8.25% per annum rate (as of mid-2025).
How do you gather relevant data for the P11D deadline?
Ahead of the P11Ds deadline, you should have almost all the relevant details at hand through your database. You can find the definitive information by following the steps outlined below.
Identify eligible P11D employees
All benefits in kind, as well as certain expenses that can be claimed, should be logged in your payroll software. Through that, you should tally up eligible employees by:
- List all employees and directors – Start with a full payroll headcount, including directors and any office holders. Have this listed exported from your payroll software or HR system. Filter the list to everyone who, throughout the tax year, may have received a benefit in kind or expense payments that have not been covered by HMRC’s approved flat rates.
- Exclude payroll benefits – If you have voluntarily registered for “payroll benefits” with HMRC, note that any benefits fully taxed through HMRC’s Paye online service should be excluded from a P11D. Payrolls partially paid should have the payroll portion recorded.
- Check PAYE settlement agreements (PSAs) and exemptions – If the stated expenses and benefits are exempt via a PSA (such as occasional staff social functions), or meet the HMRC exemption status, dismiss them from the form.
Build and maintain a centralised “expenses and benefits” register throughout the year
A business owner can only know whether an employee has expenses and benefits if reliable procedures are in place to capture them. Having a single live document that you can update with reportable benefits and expenses acquired by employees from the beginning to the end of the tax year solves this issue and ensures you’re not scrambling to meet the P11D deadline.
This can be done via the following:
- Create a master register template – Create a spreadsheet that has the following entries:
- Employee name and NI number
- The type of benefit/expense
- The start and end date
- How much does it cost the company
- How much is reimbursed
- Amount reimbursed by the employee
- Source reference (invoice, contract, etc.)
- Mandate that all benefits and expenses require authorisation – This is already likely the case, but if employers give managerial roles the power to distribute benefits in kind and expenses, ensure that they must check for authorisation and mark down the details of the transaction via the sheet.
- Update in real time – Put it into policy that whenever expenses and benefits are given out, it is to be logged in the sheet. Never wait till the end of the tax year, as this is not only time-consuming but also risks missing important articles.
- Use consistent sources – Monitor and pull data from payroll reports, HR allocations, finance systems and manager confirmations.
- Review monthly or quarterly – Check the register against both payroll and finance records to catch missing or duplicated entries. Also, ensure that when the P11D deadline is approaching, you perform a thorough cross-reference.
- Lock for filing in June – Freeze the register by mid-June, and reserve it to complete both the P11d and P11d B forms. After it is done, unlock it again.
Conclusion
The P11d deadline is not as critical as actually having the correct data on hand in preparation. Utilise company policy to mandate tracking via data for the most streamlined process.
FAQ – What are examples of expenses?
For clarity, the following are examples of what could qualify as exempt:
- Expenses – There are three types of expenses in the business, however, only taxable expenses are to be reported:
- Taxable expenses – These are paid to or on behalf of an employee, and are not exempt and therefore could be taxable. Examples include train fare from home to work, reward holiday flights and private mobile phone bills. Each of these is not exclusively business-related.
- Exempt expenses – Do not report exempt expenses as HMRC will tax them if you put them on the P11D. HMRC exemptions include all items that are wholly and exclusively necessary for the job, and not everyday wear.
- Reimbursed expenses – These cover transactions covered by the employee and claimed back later. The list is more of a grey area, as many articles have allowable parameters, whereas others are taxable. Consult a reimbursed expense list to ensure compliance.
